BILL ANALYSIS Ó SENATE JUDICIARY COMMITTEE Senator Noreen Evans, Chair 2011-2012 Regular Session AB 1354 (Huber) As Amended January 4, 2012 Hearing Date: July 3, 2012 Fiscal: No Urgency: No RD SUBJECT Civil Procedure: Discovery Objections: Privilege Logs DESCRIPTION This bill would require that if a party makes an objection based on a claim of privilege or a claim that the information sought is protected work product, the response must include sufficient factual information for other parties to evaluate the merits of that claim and, if necessary, produce a privilege log. BACKGROUND The Civil Discovery Act sets forth the procedures by which parties to a civil action obtain "discovery." (See Code of Civ. Proc. Sec. 2017.010 et seq.) Under that Act, any party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action or to the determination of any motion made in that action, if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence. One way in which a party may obtain discovery is through inspections of documents, things, and places. At the same time, a party has the right to object to a discovery demand on the basis of a privilege or work product in certain circumstances. In 2009, AB 578 (Huber) was introduced, seeking to authorize the party making a discovery demand to move for an order to require the responding party to produce a "privilege log" if the responding party objects on the basis of privilege or work product, as specified. That bill, among other things, attempted (more) AB 1354 (Huber) Page 2 of ? to define the term and would have also required the court to order the party claiming the privilege to prepare and serve a privilege log according to the terms and conditions deemed appropriate by the court, if the court, in its discretion, determined that a privilege log is necessary in order to determine the validity of the claim. The bill was not moved out of this Committee. Last year, the author introduced AB 238 (Huber, 2011), a bill that is identical to the current bill, after working extensively to address issues raised by the previous version of this bill with numerous groups, including the Judicial Council, Consumer Attorneys of California (CAOC), California Judges Association, State Bar, California Defense Counsel, and Civil Justice Association. These groups were neutral on the version of the bill that came to this Committee for review, but the bill was subsequently gutted and amended into a bill on motor vehicle conditional sale contracts. This bill would expressly require a responding party who objects to a discovery demand on the basis of a claim of privilege or work product to provide sufficient factual information in its response for other parties to evaluate the merits of that claim, including, if necessary, a privilege log. CHANGES TO EXISTING LAW Existing law , the Civil Discovery Act, provides procedures by which parties to a civil action conduct and obtain "discovery." (Code Civ. Proc. Sec. 2017.010 et seq.) Existing law provides that, unless otherwise limited by court order in accordance with the Civil Discovery Act, any party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action or to the determination of any motion made in that action, if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence. (Code Civ. Proc. Sec. 2017.010.) Existing law provides that no person has a privilege to refuse to be a witness; refuse to disclose any matter or refuse to produce any writing, object, or thing unless otherwise provided by statute. (Evid. Code Sec. 911.) Existing law allows for specified privileges, including attorney-client, physician-patient, and others. (Evid. Code Secs. 930-1063.) AB 1354 (Huber) Page 3 of ? Existing law requires the court to limit the scope of discovery if the burden, expense, or intrusiveness of that discovery clearly outweighs the likelihood that the information sought will lead to the discovery of admissible evidence. (Code Civ. Proc. Sec. 2017.020(a).) Existing law declares policy of the state underlying the work-product privilege. The policy is to both: preserve the rights of attorneys to prepare cases for trial with that degree of privacy necessary to encourage them to prepare their cases thoroughly and to investigate not only the favorable but the unfavorable aspects of those cases; and prevent attorneys from taking undue advantage of their adversary's industry and efforts. (Code Civ. Proc. Sec. 2018.020(a)-(b).) Existing law provides that a writing that reflects an attorney's impressions, conclusions, opinions, or legal research or theories is not discoverable under any circumstances. (Code Civ. Proc. Sec. 2018.030(a).) Existing law provides that the work product of an attorney, other than a writing, as described above, is not discoverable unless the court determines that denial of discovery will unfairly prejudice the party seeking discovery in preparing that party's claim or defense or will result in an injustice. (Code Civ. Proc. Sec. 2018.030(b).) Existing law enumerates the methods by which a party may obtain discovery, including oral and written depositions; interrogatories; physical and mental examinations; requests for admissions; simultaneous exchanges of expert trial witness information; and inspections of documents, things and places. (Code Civ. Proc. Sec. 2019.010.) Existing law provides the procedures and requirements by which any party may make an inspection demand. (Code Civ. Proc. Secs. 2031.010-2031.060.) Existing law requires a party to whom a demand for inspection, copying, testing, or sampling has been directed to respond to each item or category of item by either: a statement that the party will comply with the particular demand; a representation that the party lacks the ability to comply with the demand of a particular item or category of item; or an objection to the particular demand for inspection, copying, AB 1354 (Huber) Page 4 of ? testing, or sampling. (Code Civ. Proc. Sec. 2031.210(a)-(c).) Existing law provides if the responding party objects to the demand for inspection, copying, testing, or sampling of an item or category of item, the response must do both of the following: identify with particularity any document, tangible thing, land, or electronically stored information falling within any category of item in the demand to which an objection is being made; and set forth clearly the extent of, and the specific ground for, the objection. If the objection is based on a claim of privilege, the particular privilege invoked must be stated. If an objection is based on a claim that the information sought is protected work product, that claim must also be expressly asserted. (Code Civ. Proc. Sec. 2031.240(b)(1)-(2).) Existing law provides that on receipt of a response to a demand for inspection, copying, testing, or sampling, the demanding party may move for an order compelling further response to the demand, if the party deems that an objection in the response is without merit or too general. (Code Civ. Proc. Sec. 2031.310(a)(3).) Existing case law provides that a privilege log is jargon, commonly used by courts and attorneys to express the requirements of Section 2031.240 (which requires a party to identify with particularity the document to which objection is being made and set forth clearly the extent of, and the specific ground for, the objection, the particular privilege, and expressly assert if an objection is based on a claim that information sought is protected work product). Existing case law provides that the purpose of a privilege log is to provide a specific factual description of documents in aid of substantiating a claim of privilege in connection with a request for document production, so as to permit a judicial evaluation of the claim of privilege. (Hernandez v. Superior Court (2003) 112 Cal.App.4th 285, 292.) Existing case law provides that, if the responding party objects to a demand on the basis of a privilege or work-product claim, the court may require the objecting party to produce a privilege log, with information "sufficiently specific to allow a determination of whether each withheld document is or is not in AB 1354 (Huber) Page 5 of ? fact privileged." Case law also provides that a responding party is not automatically required to produce a privilege log at the time of objection. (Best Product Inc. v. Superior Court (2004) 119 Cal.App.4th 1181, 1188-1190.) Case law further provides that a tardy privilege log does not equate to waiver of any privilege, provided that the objection to discovery on the basis of privilege was expressly made in a timely manner. (Id. at 1188; Korea Data Systems v. Superior Court (1997) 51 Cal.App.4th 1513, 1517.) This bill would expressly require a responding party who objects to a discovery demand on the basis of a claim of privilege or work product to provide sufficient factual information in its response for other parties to evaluate the merits of that claim, including, if necessary, a privilege log. COMMENT 1. Stated need for the bill According to the author: Current law permits a party to a civil action to obtain discovery by inspecting documents, tangible items, and land or other property in the possession of any other party to the action. Current law also provides procedures that must be followed when the responding party objects to part or all of an inspection demand. There is no provision in the Code of Civil Procedure requiring a responding party who objects to an inspection demand on the grounds of attorney-client or work product privilege to produce a privilege log unless and until a court orders production. (Best Product Inc. v. Superior Court (2004) 119 Cal.App.4th 1181, 1188.) AB Ý1354] codifies current case law for requesting a court order requiring the production of a privilege log. This bill would require the responding party to provide sufficient factual information in its response for other parties to evaluate the merits of that claim, including, if necessary, a privilege log. Practitioners frequently refer to privilege logs but there is no common definition of a privilege log and what categories it should contain. There are some cases that justify ordering the production of a privilege log at the outset and some cases that do not justify the expense of one at all. This proposal allows the parties to agree to "opt in" or the Court to order the parties to comply. AB 1354 (Huber) Page 6 of ? 2. Discovery rights and evidentiary privileges -- balancing the right to evidence against the need for confidentiality This bill seeks to require a party who objects to a discovery demand on the basis of a claim of privilege or work product to provide sufficient factual information in its response for other parties to evaluate the merits of that claim, including, if necessary, a privilege log. Under the Civil Discovery Act, parties have the right to discovery of any matter, not privileged, that is relevant to the subject matter involved in the pending action or to the determination of any motion made in that action, if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence. There are several methods for a party to obtain discovery, such as depositions, interrogatories, and so forth; one such way is through inspections of documents, things, and places. This right of parties to conduct discovery and uncover admissible evidence is tied to the interest in introducing all relevant evidence when a matter is decided in court, which in turn stems from a general legal principle that the public has an interest and right to "every man's evidence." At the same time, the law considers certain evidence as privileged, and thereby not subject to discovery. (See Evid. Code Secs. 911, 930-1063.) These privileges include the attorney-client privilege, physician-patient privilege, spousal privilege, and others. In reviewing such statutory privileges, courts have repeatedly found that the public benefits most by protecting confidential communications in certain relationships and permitting the holder of the privilege to refuse to disclose and prevent others from disclosing the contents of those communications. These rules facilitate the purpose of those privileged relationships by removing any fear that information which is key to receiving the assistance of a doctor, lawyer, counselor, psychotherapist, spouse, or clergyman will be disclosed. Without that assurance, it is believed that many people would not appropriately seek the assistance or share the information needed to enable proper assistance, to the detriment of their physical health, mental health, or legal rights. Still, evidentiary privileges have been carefully limited to balance the need for confidentiality with that fundamental right of the public to every man's evidence. AB 1354 (Huber) Page 7 of ? Relatedly, under existing law, a party has the right to object to a discovery demand on the basis of privilege or work product in certain circumstances. In fact, a court must limit the scope of discovery if it determines that the burden, expense, or intrusiveness of that discovery clearly outweighs the likelihood that the information sought will lead to the discovery of admissible evidence. (Code Civ. Proc. Sec. 2017.020(a).) At the same time, the claim of privilege alone is not sufficient to prohibit discovery; an objecting party must further make a showing that the privilege is rightfully claimed. As a result, Section 2031.240(b)(2) of the Civil Discovery Act provides that if a party responding to a demand for inspection, copying, testing, or sampling objects to that demand, that party must set forth clearly the extent of, and the specific ground for, the objection. If the objection is based on a claim of privilege, the particular privilege invoked must be stated, as must any claim that the information sought is protected work product. (Code Civ. Proc. Sec. 2031.240(b)(1)-(2).) In effect, "Ýt]he law attempts to find a balance between these competing interests in discovery and the assertion of privilege by requiring a party objecting to document production to "identify with particularity" any document as to which it makes an object and "set forth clearly the extent of, and specific ground for, the objection in accordance with Ýthis section]." (Kaiser Foundation Hospitals v. Superior Court (1998) 66 Cal.App.4th 1217, 1228.) This bill seeks to codify case law by adding to that provision of existing law that a party must provide sufficient factual information when objecting to a demand for inspection based on privilege or work product, and that privilege logs may be required, if necessary. 3. Privilege logs under existing law The author maintains that this bill would simply codify that privilege logs may be required of a party objecting to an inspection demand based on privilege or work product. In accordance with current case law, after a discovery demand is made, a party may object to the discovery of specific requested items, or any part of an item, so long as the response identifies the item with particularity and clearly sets the grounds for objection. If the requesting party does not find those stated grounds satisfactory to demonstrate that the AB 1354 (Huber) Page 8 of ? privilege exists, it may move for an order compelling the further response. As a result, the question arises as to when and for what purpose privilege logs are to be used. Ultimately, case law concludes that while a privilege log can be used at any point on a voluntary basis or as a result of an agreement between parties, courts may require the production of a privilege log at the point that a motion is made to compel "further response," in order to help evaluate the claim of privilege. (Best Product v. Superior Court (2004) 119 Cal.App.4th 1181, 1189-1190; Hernandez v. Superior Court (2003) 112 Cal.App.4th 285, 292.) A party is not automatically required to produce a privilege log in its response under Section 2031.310(b)(2) of the Code of Civil Procedure to the requesting party's demand for inspection. (Best Product, 119 Cal.App.4th at 1190, see Comment 3b below for further discussion.) As discussed below courts appear to already have discretion to both compel the production of a privilege log when appropriate and to define what a privilege log means based upon the circumstances. To avoid any inadvertent interference with a court's discretion under existing case law, the author proposes a clarifying amendment, discussed in Comment 3(c), to avoid such interference. a. Privilege log, explained As noted in Comment 2b, the term "privilege log" does not appear and is not defined anywhere in the Code of Civil Procedure. (See e.g. Hernandez v. Superior Court (2003) 112 Cal.App.4th 285.) In Hernandez v. Superior Court, the Court of Appeal explained that nowhere in the Code of Civil Procedure is the term used or explained. "The expression is jargon, commonly used by courts and attorneys to express the requirements of subdivision (g)(3) of section 2031." That section, since renumbered to Section 2031.240, requires a responding party who objects to the demand for inspection of a document based upon a claim of privilege: (1) identify with particularity the document to which objection is made, and (2) set forth clearly the extent of, and the specific ground for, the objection; state any particular privilege claimed; and expressly assert any objection based on a claim that information sought is protected work product. (112 Cal.App.4th at 292.) AB 1354 (Huber) Page 9 of ? As described by the courts, the purpose of a privilege log is to provide a specific factual description of documents in aid of substantiating a claim of privilege in connection with a request for document production. The purpose of providing a specific factual description of documents, in turn, is to permit a judicial evaluation of the claim of privilege. (Id.) b. Case law on the application of privilege logs In Best Product v. Superior Court (2004) 119 Cal.App.4th 1181, the Court of Appeal held that the trial court misapprehended the stage of a proceeding at which a privilege log becomes relevant. In that case, the trial court had found that defendant's failure to provide a privilege log in its response to the plaintiff's demand constituted a waiver of its right to assert the attorney-client and work product privileges, even though the defendant did assert the both privileges in its response objecting to discovery in a timely manner. Reversing that decision, the Court of Appeal determined that there was "absolutely no requirement that a privilege log be tendered at this point of the discovery proceedings," referencing at the time of the initial response. (Id. at 1188.) The court explained that the need for a privilege log could have arisen if the plaintiff, who had made the discovery demand, had moved to compel further responses to contest the defendant's conclusory attorney-client and work product inspection under the applicable statutory provision. But the plaintiff in that case did not do so. (112 Cal.App.4th at 1189 (emphasis added).) The relevant statute, Section 2031(m), was substantially similar to that of existing law today, and provided that: "If the party demanding an inspection, on receipt of a response to an inspection demand, deems . . . (3) an objection in response is without merit, or too general, that party may move for an order compelling further response to the demand." (See Code Civ. Proc. Sec. 2031.310(a)(3), providing that on receipt of a response to a demand for inspection, copying, testing, or sampling, the demanding party may move for an order compelling further response to the demand, if the party deems that . . . (3) an objection in the response is without merit or too general.) Thus, under existing case law, if the responding party objects to a demand on the basis of a privilege or work-product claim, in evaluating that objection, the court may require the objecting party to produce a privilege log, with information AB 1354 (Huber) Page 10 of ? "sufficiently specific to allow a determination of whether each withheld document is or is not in fact privileged." However, a responding party is not automatically required to produce a privilege log at the point of objection to claim the privilege. (Best Product Inc. 119 Cal.App.4th 1181, 1188-1190; see also Korea Data Systems v. Superior Court (1997) 51 Cal.App.4th 1513, 1517.) This bill seeks to codify those same principles and provide clarity for future cases on the use and application of privilege logs, while also adding the word "privilege logs" to the Code of Civil Procedure for the first time. c. Author's amendment to clarify the intent of the bill and avoid unintended consequences Committee staff notes that it is important that the right to claim a privilege not be waived by the production of a privilege log, which often may contain information that an attorney would not otherwise reveal based on confidential communications. For example, the time a communication is made to a particular party, often included in a privilege log, may be considered privileged itself under the circumstances. Moreover, absent the clarifying amendment discussed below, codification of the term "privilege log," without a correlating definition or detailed guidance for the courts, could be construed to be a substantive change in law with unknown consequences. Accordingly, the following author's amendment would clarify the intent of the bill, and ensure that it is not construed to change case law with respect to privilege logs. Author's Amendment : On page 3, line 21, after (c) insert "(1)" On page 3, after line 25, insert "(2) It is the intent of the Legislature to codify the concept of a privilege log as that term is used in California case law. Nothing in this subdivision shall be construed to constitute a substantive change in case law." Support : Consumer Attorneys of California AB 1354 (Huber) Page 11 of ? Opposition : None Known HISTORY Source : Conference on California Bar Associations Related Pending Legislation : None Known Prior Legislation : AB 238 (Huber, 2011) See Background. AB 578 (Huber, 2009) See Background. Prior Vote : Assembly Floor (Ayes 64, Noes 0) Assembly Judiciary Committee (Ayes 10, Noes 0) **************