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← 173 FRD 459 - Glidden Co. v. Jandernoa

Glidden Co. v. Jandernoa’s Empirical Analysis

1997

Citation profile

18
cited by 18 later decisions
2
states following
February 2018
most recently cited

1 federal appellate · 1 district · 2 state decisions

How this case has been cited

Cited by 18 later decisions — most recently February 2018

1 federal appellate · 1 district · 2 state decisions

120199720002010decided

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.

Relationships

Applies 28 U.S.C. § 1404

Relies on Klaxon Co. v. Stentor Electric Manufacturing Co. · Van Dusen v. Barrack · Babcock v. Jackson · Clark v. United States · Henderson v. Brown

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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “The universal rule of law, expressed in a variety of contexts, is that the parent and subsidiary share a community of interest, such that the parent (as well as the subsidiary) is the “client” for purposes of the attorney-client privilege. See Crabb v. KFC Nat’l Management Co., No. 91-5474, 1992 WL 1321 (6th Cir. Jan.6, 1992) (“ ‘The cases clearly hold that a corporate ‘client’ includes not only the corporation by whom the attorney is employed or retained, but also parent, subsidiary and affiliate corporations.’ ” (quoting United States v. AT & T, 86 F.R.D. 603 , 616 (D.D.C.1979))). Consequently, disclosure of legal advice to a parent or affiliated corporation does not work a waiver of the confidentiality of the document, because of the complete community of interest between parent and subsidiary. Id. at . Numerous courts have recognized that, for purposes of the attorney client privilege, the subsidiary and the parent are joint clients, each of whom has an interest in the privileged communications. See, e.g., Polycast Tech. Corp. v. Uniroyal, Inc., 125 F.R.D. 47 , 49 (S.D.N.Y.1989); Medcom Holding Co. v. Baxter Travenol Lab., 689 F.Supp. 841 , 842 (N.D.Ill. 1988).”
    1 later decision quote this exact passage
  2. “Because the attorney-client privilege belongs to the client, it would be perverse to allow the privilege to be asserted against the client.”
    1 later decision quote this exact passage
  3. “directors have a right to access attorney communications of the company relating to the time that they served as directors,”
    1 later decision quote this exact passage

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.