163 Mich. App. 447 - Ravary v. Reed’s Empirical Analysis

Citation profile

10 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “reflects the Legislature's determination that broad protection is to be accorded the private detective-client relationship. Any communication by a client to a licensee and any information secured in connection with an assignment for a client is privileged.”

   2 later decisions quote this exact passage
   e.g. 256 Mich. App. 39 - In Re Investigation of Death of White · Ubiquiti Networks, Inc. v. Kozumi USA Corp.

2. “§ 338.840. Divulging of information; willful sale of or furnishing false information; penalty; privileged communications; notice and hearing. Sec. 20. (1) Any person who is or has been an employee of a licensee shall not divulge to anyone other than his or her employer or former employer, or as the employer shall direct, except as he or she may be required by law, any information acquired by him or her during his or her employment in respect to any of the work to which he or she shall have been assigned by the employer. Any employee violating the provisions of this section and any employee who willfully makes a false report to his or her employer in respect to any work is guilty of a misdemeanor. (2) Any principal, manager, or employee of a licensee who willfully furnishes false information to clients, or who willfully sells, divulges, or otherwise discloses to other than clients, except as may be required by law, any information acquired during employment by the client is guilty of a misdemeanor and is subject to summary suspension of license and revocation of license upon satisfactory proof of the offense to the department. Any communications, oral or written, furnished by a professional or client to a licensee, or any information secured in connection unth an assignment for a client, is considered privileged with the same authority and dignity as are other privileged communications recognized by the courts of this state. (3) Suspension, revocation, denial, or other action ”

   1 later decision quote this exact passage
   e.g. Ubiquiti Networks, Inc. v. Kozumi USA Corp.

3. “In recent times in the United States, however, legislation has been sought, here and there successfully, to establish new privileges. Most of these attempts have been made by organized occupational groups who believe that for the protection of their own particular interests a privilege is needed and is justified. In no instance has it been made to appear that the occasional disclosure, in judicial proceedings, of the communication sought to be kept secret would be injurious to the general exercise of the occupation, or that all the conditions exist which justify a general privilege (§ 2285 supra). Statutes which do no more than penalize general breaches of confidence — e.g., all statutes respecting disclosure by detectives n. 19 ... — explicitly permit disclosure in judicial proceedings. They should be distinguished from statutes erecting testimonial privileges. n.19 Four states have statutes making it unlawful for a private detective to divulge information acquired on behalf of a client except as he may be required by law so to do. Cal. Bus. & Prof. Code § 7538 ; Mass. Gen. Laws Ann. c. 147, § 28 (1958) (construed by Attorney-General v. Pelletier, 240 Mass. 264 , 134 N.E. 406 [407] (1922), not to apply to exclude testimony at a trial); N.Y. Gen. Bus. Law § 82 (construed by People v. Roach, 215 N.Y. 592 , 109 N.E. 682 [618] (1915), not to apply to exclude testimony at legal proceedings); Pa. Stat. Ann. tit. 22, § 24 (1955).”

   1 later decision quote this exact passage
   e.g. Ubiquiti Networks, Inc. v. Kozumi USA Corp.