St. John's Law Review

The Alienability of Evidentiary Privileges: Of Property and Evidence, Burden and Benefit, Hearsay and Privilege

By: Edward J. Imwinkelried

Under English law, when a natural person transfers title to property to a new titleholder, the new titleholder also takes the evidentiary privilege attaching to any communications between the prior titleholder and an attorney concerning the transferred property.  This view that the attorney-client privilege should transfer automatically by operation of law seemingly categorizes the attorney-client privilege as a mere property right; however, this privilege was not intended to protect property.  Rather, it was meant to protect confidential communications between a client and his attorney.

American jurisprudence has recognized the privacy interests at the foundation of the attorney-client privilege.  In the United States, a new titleholder will not automatically obtain the evidentiary privilege in a property transfer.  To allow such a conveyance would undermine the purpose of the privilege, and may place it in the hands of a buyer who may have little or no prior relationship with the former titleholder and thus no knowledge of that person’s privacy concerns.  For similar reasons, allowing a titleholder to voluntarily alienate his attorney-client privilege would be contrary the policy behind this privilege.  It would become a bargaining chip that a transferee would undoubtedly ask for in the exchange.  If the transferee happens to receive the privilege in the conveyance, he will undoubtedly use it to protect his own interests rather than those of the prior titleholder.

The purpose of this Article is to initiate a discussion of that question and to share some preliminary thoughts on the topic.  The thesis of this Article is that a natural person’s evidentiary privileges should be inalienable both by operation of law and even by act of the parties.  To develop that general thesis, the Article addresses four specific topics.  The initial part of the Article analyzes the threshold question of whether, in terms of the alienability of privileges, it is justifiable to treat natural persons and entities differently.  Positing that differential treatment is warranted, the next part of the Article deals with the issue of whether the attorney-client privilege of a property owner should automatically pass to a successor titleholder.  The third part discusses the related question of whether the privilege ought to be alienable by a voluntary act of the original holder.  The final part of the Article asks whether the preceding analysis is, in effect, “much ado about nothing.”  Assuming that the general norm ought to be inalienability, should the original holder be able to circumvent that norm by the simple expedient of appointing the new titleholder his or her agent for the purpose of asserting or waiving the privilege?  At the end of this line of analysis, hopefully this Article will not only construct a case for its general thesis, but even more importantly, yield some insight into the very nature of evidentiary privileges in American law.