Ralls v. United States case brief

Ralls v. United States case brief summary
52 F.3d 223 (1995)

CASE SYNOPSIS

Appellant criminal defense attorney sought review of the judgment of the United States District Court for the District of Arizona, which denied in part his motion to quash a grand jury subpoena that required him to provide information regarding a client/fee-payer. Appellant also challenged the district court's order holding him in contempt for failure to provide information pursuant to court orders.

CASE FACTS
The government issued a grand jury subpoena to appellant criminal defense attorney, seeking information as to who hired and paid for appellant to represent defendant in a corollary criminal matter. The district court denied appellant's motion to quash the subpoena and held him in contempt when he failed to testify. Appellant challenged the district court's orders, contending his retainer agreement was covered by attorney-client privilege.

DISCUSSION

• The court reversed and remanded, holding that the subpoena be quashed in its entirety on the basis of attorney-client privilege. 
• The court further reversed the district court's order holding appellant in contempt for failing to comply with the subpoena.

CONCLUSION
The court ordered the government's subpoena of appellant criminal defense attorney quashed because it requested fee agreement information that was inextricably linked to privileged communication.


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