Neuharth v. Quinn

23 Va. Cir. 252, 1991 Va. Cir. LEXIS 43
CourtVirginia Circuit Court
DecidedMarch 12, 1991
DocketCase No. (Law) 10578
StatusPublished
Cited by4 cases

This text of 23 Va. Cir. 252 (Neuharth v. Quinn) is published on Counsel Stack Legal Research, covering Virginia Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Neuharth v. Quinn, 23 Va. Cir. 252, 1991 Va. Cir. LEXIS 43 (Va. Super. Ct. 1991).

Opinion

By JUDGE THOMAS D. HORNE

This case comes before this Court on the Quinns’ Motion to Disqualify John Flannery, II, Esq., as counsel for the Neuharths. Mr. Flannery was retained by the Neuharths to represent them after their former counsel, Nixon & Hargrave, had withdrawn at the Neuharths’ request. After due consideration of the Quinns’ motion, the Neuharths’ Motion in Opposition, Mr. Flannery’s Sworn Opposition to Motion to Disqualify, and testimony and exhibits offered on behalf of the parties, the Court finds that Mr. Flannery is disqualified from this case after discussion of the issues stated below.

A. Mr. Quinn’s alleged meeting and discussion of the details of this case with Mr. Flannery.

As in State ex rel. Taylor Associates v. Nuzum, 330 S.E.2d 677, 680 (W. Va. 1985), the Court is "faced here with a tempest in a teapot." Mr. Flannery contends [253]*253that the Quinns never approached him about this case. "Nothing like that ever happened," he alleges.

On the other hand, the Quinns allege that Mr. Quinn approached Flannery, whom Mr. Quinn considered to be his lawyer, after being served with the suit papers in the instant action and that Mr. Flannery reviewed the suit papers and entered into a discussion of the matter surrounding the law suit.

Mr. Flannery is adamant that no such conversation ever transpired. The court in Taylor held that because Mrs. Taylor initially contacted Mr. Underwood (the attorney) and "alleged" she revealed to him all the information she had about the case, Mr. Underwood was barred from representing Mrs. Taylor’s opponents "without compromising either the representation of his new clients or sacrificing his duty of confidentiality to Mrs. Taylor." 330 S.E.2d 677, 681, citing DR 4-101(B). Note that the court did not find that Mrs. Taylor actually did reveal information to Mr. Underwood. The court based its ruling on Mrs. Taylor’s allegations. However, the Court recognizes that in Taylor, Mr. Underwood had "no recollection" of such a conversation.

The Virginia Legal Ethics Opinions are fraught with caution against an attorney accepting a case in which a former or current client has related confidential information concerning that matter to the attorney. For example, it is:

improper for an attorney to accept a case where a member of the firm had previously consulted with opposing party concerning the possibility of representation unless the opposing party consents to such representation.

Ethics Opinion Number 318, DR 5-105(D).

Once a mere potential or actual client discusses litigation with an attorney, the court need not find that the attorney in fact obtained confidential information. Communication of confidential information is simply presumed. NCK Organization LTD v. Bergman, 542 F.2d 128, 134 (2d Cir. 1976) (court may assume that attorney attains confidential data on former client if representation occurs in substantially related area); Richardson v. [254]*254Hamilton International Corporation, 469 F.2d 1382, 1385 (3d Cir. 1972) cert. den., 411 U.S. 986 (former client need not prove attorney possessed confidential information); Emile Industries v. Patent, Inc., 478 F.2d 562, 565 (2d Cir. 1973) (same); Cord v. Smith, 338 F.2d 516, 518 (9th Cir. 1964) (court may disqualify attorney from representing new client in substantially related matter even if no proof exists that attorney has confidential information); see also Castle and Foster, The New Model Rules: Conflicts and Lawyer Disqualification, Nat’l L. J., Feb. 6, 1984.

The Court cannot conclude upon the evidence before it that such a discussion ever occurred and, therefore, cannot disqualify Mr. Flannery for this reason.

B. Even if the Quinns did not discuss this particular case with Mr. Flannery, should he be disqualified because he may have obtained pertinent confidential information from the Quinns, during his representation of them on prior matters, that will aid him in representing the Neuharths?

The mere fact that a lawyer represented a person who is now the adverse party in a suit brought by the lawyer on behalf of another client is. not sufficient to warrant disqualification of the lawyer on ethical grounds. However, a violation of DR 4-101(B) might result if the lawyer possessed confidential information obtained from the first client.

Legal Ethics Opinion 441, DR 5-105(C), (D).

Mr. Flannery notes that his representation of the Quinns on several other occasions should not preclude him from representing an adverse party now. However, it has been said that "it is the potential manifestation of the conflict with which [the court is] concerned." In re Stancraft Corp., 39 B.R. 748, 751, n. 5 (Bkrtcy. E.D. Va. 1984), 10 Collier 2d 1061, citing In re Bohack Corp., 607 F.2d 258, 263 (2d Cir. 1979). Therefore, "doubts about the propriety of representing clients with potentially adverse interests should be resolved against continuing or accepting the representation" of another client. In re Stancraft Corp., 39 B.R. 748, 754.

[255]*255Though Mr. Flannery may no longer represent the Quinns, he is still bound by an attorney’s obligation to preserve a client’s confidences. Ethical Consideration EC 4-6. Mr. Flannery’s ongoing relationship with the Quinns over several years and his representation of them in writing their wills, in Miller Brothers Construction Co. v. Thomas D. Quinn, et al., Chancery No. 11773 (Loudoun County Cir. Ct.), in Piedmont v. Quinn, Civ. Action No. 85-CP-26-2126 (South Carolina), and in releasing Mr. Quinn from Springwood, unfortunately raises the specter of conflict because of potential disclosures.

An attorney should not accept or continue employment if the interests of another client may impair the independent professional judgment of an attorney. In re Stancraft Corp., 39 B.R. 748, 753; DR 5-105 (1983). In the instant case, substantial doubt can be raised as to whether Mr. Flannery’s independent professional judgment will be preserved despite his relationship with both parties on the opposite sides of the current conflict. Taken in conjunction with the other facts in this case, these prior representations and the potential access to confidential information serve to disqualify Mr. Flannery.

C. Should Mr. Flannery be disqualified if the Quinns have shown that there is a substantial relationship between his prior representation of them and the issues raised in his representation of the Neuharlhs?

The existence of an attorney-client relationship and the concomitant presumption of an exchange of confidences is not enough to require disqualification.

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

Related

Yukon Pocahontas Coal Co. v. Consolidation Coal Co.
72 Va. Cir. 75 (Buchanan County Circuit Court, 2006)
Arriba Corp. v. Bostic
69 Va. Cir. 505 (Norfolk County Circuit Court, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
23 Va. Cir. 252, 1991 Va. Cir. LEXIS 43, Counsel Stack Legal Research, https://law.counselstack.com/opinion/neuharth-v-quinn-vacc-1991.