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Sandra T.E. v. South Berwyn School District 100

Citation: 310 F. App'x 927Docket: No. 08-3344

Court: Court of Appeals for the Seventh Circuit; February 24, 2009; Federal Appellate Court

Narrative Opinion Summary

Appellants Sidley Austin LLP and South Berwyn School District 100 challenge a lower court order mandating Sidley to release notes and memoranda from interviews of school district employees and third-party witnesses, which were gathered during an internal investigation commissioned by the School Board. The appeal was heard on February 24, 2009, with plaintiffs-appellees requesting a swift decision to aid in their trial preparations for August 2009. The appellate court determined that the materials in question are protected by both attorney-client privilege and the work-product doctrine, leading to a reversal of the district court's order. An opinion detailing the rationale will be issued subsequently.

Legal Issues Addressed

Attorney-Client Privilege

Application: The appellate court determined that the notes and memoranda from interviews conducted during an internal investigation are protected by attorney-client privilege, thereby exempting them from mandatory disclosure.

Reasoning: The appellate court determined that the materials in question are protected by both attorney-client privilege and the work-product doctrine, leading to a reversal of the district court's order.

Reversal of Lower Court Order

Application: The appellate court reversed the district court’s order that had mandated the release of privileged materials, supporting the protection of such documents under established legal doctrines.

Reasoning: The appellate court determined that the materials in question are protected by both attorney-client privilege and the work-product doctrine, leading to a reversal of the district court's order.

Work-Product Doctrine

Application: The court held that the materials prepared by Sidley Austin LLP during the internal investigation for the School Board are covered under the work-product doctrine, preventing their release to the plaintiffs.

Reasoning: The appellate court determined that the materials in question are protected by both attorney-client privilege and the work-product doctrine, leading to a reversal of the district court's order.