No. 21-1397October Term 2022Decided Jan 23, 2023
In re Grand Jury
A grand jury subpoenaed documents from a company and its law firm, who withheld certain communications that contained both legal and non-legal advice.
Case status
- Current stage
- Decided
- Latest event
- Decision released Jan 23, 2023
- What it's about
A grand jury subpoenaed documents from a company and its law firm, who withheld certain communications that contained both legal and non-legal advice. The Supreme Court initially took the case to decide when such dual-purpose communications are protected by attorney-client privilege, but ultimately dismissed the case without a ruling.
Question presented
When are dual-purpose communications that contain both legal and non-legal advice protected by attorney-client privilege?
- Case path
United States Court of Appeals for the Ninth Circuit / Decision released Jan 23, 2023
- Area
Decided Supreme Court case
Documents
Related cases




Grounding
- Grounding
- Primary-source trail available.
- Note
- Plain-English explainer. Official filings and opinions remain authoritative.
- Checked
- Apr 30, 2026
- Method
- Methodology