Maddox v. Greene Cty. Bd. of Commrs.

2014 Ohio 1541
CourtOhio Court of Appeals
DecidedApril 11, 2014
Docket2013-CA-71
StatusPublished
Cited by2 cases

This text of 2014 Ohio 1541 (Maddox v. Greene Cty. Bd. of Commrs.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maddox v. Greene Cty. Bd. of Commrs., 2014 Ohio 1541 (Ohio Ct. App. 2014).

Opinion

[Cite as Maddox v. Greene Cty. Bd. of Commrs., 2014-Ohio-1541.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT GREENE COUNTY

ALICE MADDOX : : Appellate Case No. 2013-CA-71 Plaintiff-Appellee : : Trial Court Case No. 13-CV-444 v. : : BOARD OF COMMISSIONERS OF : (Civil Appeal from GREENE COUNTY, OHIO : (Common Pleas Court) : Defendant-Appellant : : ...........

OPINION

Rendered on the 11th day of April, 2014.

...........

JOHN R. FOLKERTH, JR., Atty. Reg. #0016366, and PAUL M. COURTNEY, Atty. Reg. #0020085, Weprin Folkerth & Routh LLC, 109 North Main Street, 500 Performance Place, Dayton, Ohio 45402 Attorneys for Plaintiff-Appellee

LAWRENCE E. BARBIERE, Atty. Reg. #0027106, Schroeder, Maundrell, Barbiere & Powers, 5300 Socialville Foster Road, Suite 200, Mason, Ohio 45040 Attorney for Defendant-Appellant

.............

HALL, J.,

{¶ 1} The Greene County Board of Commissioners (“Board”) appeals from the trial

court’s denial of its motion for a protective order to prohibit deposition questioning of former 2

commissioner Marilyn Reid. In its sole assignment of error, the Board challenges the trial court’s

denial of a protective order.

{¶ 2} The record reflects that plaintiff-appellee Alice Maddox sued the Board in June

2013, alleging assorted violations of R.C. 121.22, Ohio’s open-meeting act or “sunshine law,”

between October 2010 and December 2012, and continuing up to the filing of the complaint.1

(Doc. #1). In its answer, the Board asserted, as an affirmative defense, “that at all times pertinent

it acted * * * upon advice of counsel[.]” (Doc. #13 at 15). Thereafter, Maddox deposed Reid,

who had served as a commissioner on the Board during the relevant time period. At one point

during the August 5, 2013 deposition, she was asked whether she was aware during her second

term as a commissioner that R.C. 121.22 required a record to be kept of public meetings.2 (Doc.

#28, Reid depo. at 28). Reid responded that she had not become aware of the need to keep

meeting records “until just recently.” (Reid depo. at 28). When asked how she became aware of

the requirement, Reid responded that county administrator Howard Poston “told us.” (Id.). Reid

recalled that an attorney, Elizabeth Ellis, had been in the room at the time. (Id. at 28-29). At that

point, counsel for the Board objected on the basis of attorney-client privilege. (Id.). Maddox’s

counsel responded that assertion of the advice-of-counsel affirmative defense waived the

privilege. (Id. at 29). Reid then stated that the incident had occurred sometime before September

2012. She added that the advice about keeping meeting records actually may have been provided

1 According to Maddox’s 139-paragraph complaint, the earliest alleged violation occurred on October 12, 2010. (Doc. #1 at ¶64). The latest alleged violation occurred in December 2012 and continued up to the filing of the complaint in June 2013. (Id. at ¶ 131-132, 139). 2 This question appears to be related to allegations in Maddox’s complaint that the Board held dozens of improper, private “work-session” meetings between October 2010 and November 2012, and continuing up until the filing of the lawsuit in June 2013, where minutes were not kept. (Doc. #1 at ¶ 63-126). 3

by Ellis, a county prosecutor, rather than Poston. Reid was unsure who told her and admitted that

she really “didn’t know.” (Id. at 30). In any event, Reid was instructed not to answer questions

about what she had been told. (Id. at 41). At the conclusion of the deposition, counsel for the

Board summarized his objection to Reid answering. He explained:

* * * The question that was asked related to advice that was given by the

prosecutor to Ms. Reid in her capacity as a commissioner shortly before

September 2012 when minutes began being kept for these work sessions[.] Ms.

Reid was permitted to answer that she never discussed the issues with an attorney

prior to that meeting with Ms. Reid and prior to June 1 of 2012. So she was

permitted to answer that question but we are taking the position that the advice

that was given prior to the September of 2012 meeting when minutes began being

kept, that is still protected by the attorney-client privilege, that has not been

waived, so we’re not going to permit her to answer the questions from that point.

(Reid depo. at 42).

{¶ 3} The Board placed the issue before the trial court through a motion for a

protective order. (Doc. #29). The trial court overruled the motion, holding that assertion of an

advice-of-counsel defense constituted an “express waiver” of the attorney-client privilege under

R.C. 2317.02(A). The trial court then added: “* * * [T]he particular advi[c]e the witness avers to

in her testimony appears to be statements by the County Administrator, not the Board’s legal

counsel. The fact that one’s attorney is present when statements by third parties are made, does

not implicate the attorney client privilege.” (Doc. #31 at 1-2).

{¶ 4} On appeal, the Board raises several arguments. First, it contends the trial court

erred in finding a waiver of the attorney-client privilege under R.C. 2317.02. Specifically, the 4

Board claims asserting advice of counsel as an affirmative defense does not constitute a waiver

under the statute. Second, the Board argues against finding an implied waiver of the

attorney-client privilege under common law. Third, the Board asserts that Reid’s deposition

testimony did not waive the privilege. Fourth, the Board maintains that the presence and

participation of county administrator Poston during the allegedly privileged communications did

not waive the privilege.

{¶ 5} “The burden of showing that evidence ought to be excluded under the

attorney-client privilege rests upon the party asserting the privilege.” (Citations omitted) MA

Equip. Leasing I, L.L.C. v. Tilton, 2012-Ohio-4668 , 980 N.E.2d 1072, ¶ 21 (10th Dist.). “‘In

Ohio, the attorney-client privilege is governed by statute, R.C. 2317.02(A), and in cases that are

not addressed in R.C. 2317.02(A), by common law.’” Jackson v. Greger, 110 Ohio St.3d 488,

2006-Ohio-4968, 854 N.E.2d 487, ¶7, quoting State ex rel. Leslie v. Ohio Hous. Fin. Agency, 105

Ohio St.3d 261, 2005-Ohio-1508, 824 N.E.2d 990, ¶ 18. On its face, R.C. 2317.02(A) involves a

testimonial privilege and only precludes an attorney from testifying on matters covered by the

attorney-client privilege. Id. at ¶ 21-22 (Lanzinger, J., concurring). In Jackson, however, the Ohio

Supreme Court interpreted the statute more broadly, reasoning that it applies to any

communication directly between an attorney and a client. Id. at ¶ 7. Where the statute applies, the

Jackson court opined that common-law doctrines involving implied waiver of the privilege are

inapplicable. ¶ 11-12. In such a case, the statute provides the only two means by which the

privilege may be waived: (1) express consent of the client or (2) the client’s voluntary testimony

on the same subject. Id. at ¶ 12.

{¶ 6} The Board argues that the present case is governed by the statute and, therefore,

that common-law implied waiver doctrines do not apply. Moreover, the Board argues that 5

asserting advice of counsel as an affirmative defense does not constitute express consent or

voluntary testimony. The Board also argues that Reid’s deposition testimony was not voluntary

and, in any event, that a single commissioner cannot waive a privilege held by the Board as a

whole.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Brunson
2022 Ohio 4299 (Ohio Supreme Court, 2022)
Mancz v. McHenry
2021 Ohio 82 (Ohio Court of Appeals, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
2014 Ohio 1541, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maddox-v-greene-cty-bd-of-commrs-ohioctapp-2014.