U.S. v. Legal Servs. of New York City

No. 00-0241 (D.C. Dist. Ct. June 14, 2000) ; Clearinghouse Number: 52803

Description

Legal Services Programs Must Disclose Client Names to Legal Services Corporation Office of the Inspector General

Abstract

The district court granted summary enforcement of administrative subpoenas issued by the Office of the Inspector General of the Legal Services Corporation, requiring two legal services programs to produce the names of clients and their corresponding legal problem codes. Legal Services of New York and Legal Aid Bureau refused; they argued that revealing client names, which could be linked to previously disclosed problem codes, would violate attorney-client privilege and ethics rules. Although the Office of the Inspector General developed a screening procedure to prevent anyone in its office from making such links, Legal Services of New York furnished only “unique client identifiers”; Legal Aid Bureau furnished client names only for those cases where the information had been disclosed to a third party. The court held that the attorney-client privilege did not generally protect a client’s identity or the general purpose of legal work performed and that the plain language of the 1996 Omnibus Appropriations Act required disclosure of client names. It noted, however, that it was rejecting only “a blanket assertion of privilege” and that there could be individual clients on whose behalf privilege could legitimately be claimed. Although it agreed with respondents that anonymous client identifiers could adequately meet the Office of the Inspector General’s needs, and opined that such an approach would be “less problematic” and “more cost-effective,” the court granted the petition for summary enforcement because the information subpoenaed was relevant and within the Office of the Inspector General’s authority.

Additional Information

Docket Date
2000-06-14 00:00:00+00:00

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