St. John's Law Review

Turning Out The “Light Of Reason And Experience”: The Selective Waiver Doctrine And Proposed Federal Rule Of Evidence

By Michelle Lambert

The current Federal Rules of Evidence state that common law controls privileges. The attorney-client privilege allows clients to communicate with their attorneys with confidence that these communications will not later be admissible in judicial proceedings.  As a result, the judiciary has strictly and narrowly construed the privilege to minimize the exclusion of relevant testimony at trial.  Almost always if the attorney or client later discloses a privileged communication to a third party, the privilege is waived and the communication is no longer protected from disclosure in future litigation.  Yet, one circuit court of appeals allowed the attorney-client privilege to apply to communications that had been divulged to the government during an investigation.

This piece examines the selective waiver doctrine and its controversial inclusion in proposed Federal Rule of Evidence 502.  The author compares the selective waiver doctrine with the attorney-client privilege in justification, purpose, and execution.  These comparisons demonstrate that not only does the selective waiver doctrine fail to display any similarities to elements of the attorney-client privilege, the doctrine creates an entirely new government-investigatory privilege.  And when compared to other privileges, the author concludes that judicial recognition of a government-investigatory privilege would not stand.  Finally, this piece discusses the controversial inclusion of the selective waiver doctrine in a proposed Federal Rule of Evidence—which defies the judgment of every circuit court of appeals except for one–even though the Federal Rules mandate that the judiciary controls the law of privileges.