Public-domain · open source
OpenJurist

119 Ohio App. 3d 322

695 N.E.2d 292

Phillips v. Haidet

Ohio Court of Appeals

Decided April 24, 1997

Ohio Court of Appeals · decided 1997-04-24

Good law ✅— No negative treatment on recordhow we know

Decided 1997-04-24

How this case has been cited

Cited by 35 later decisions — most recently November 2021 · most notably 143 Ohio App. 3d 102 - Sayyah v. Cutrell (2001), 165 Ohio App. 3d 742 - Luce v. Alcox (2006)

31 state decisions

1701997200020102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

Shaw, Judge,

¶1 dissenting.

¶2 The majority presents a thorough argument in defense of a litigant’s right to counsel of choice. However, I remain troubled that despite our affirmation of the need to preserve attorney-client confidentiality, several of the intermediate state appellate decisions cited by the majority, ostensibly upon the issue of a substantial relation of subject matter, in actuality appear to require proof of a conflict in confidentiality interests between the former representation and the current litigation. This would seem to significantly defeat the confidentiality protection if the former client is only required to disclose it anyway, in an effort to prove a substantial relation in subject matter.

¶3 In short, it seems to me that the protection of attorney-client confidentiality and the need to promote the complete confidence of the public in our adversarial legal system are interests that should supersede a litigant’s right to counsel of choice in civil litigation. As a result, I am persuaded that the “appearance of impropriety” standard utilized by the trial court is the better approach for the balancing of these important interests. In any event, I am not convinced that the trial court’s decision constitutes an abuse of discretion in this case.

¶4 For the foregoing reasons, I respectfully dissent. I would affirm the judgment of the trial court.

/119/ohioapp3d/322 · .json · Public domain