Riggs National Bank of Washington, D. C. v. Zimmer

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that a legal memorandum prepared at the request of a trustee was discoverable by the plaintiff-beneficiaries because the beneficiaries were the ultimate or real clients for whom the memorandum was prepared
• noting that payment of firm from trust assets “is a significant factor” in deciding who are “the real clients.”
• discussing whether attorney-client privilege bars disclosure by trustee to trust beneficiary of legal memoranda prepared by lawyer at trustee’s request
• looking to the source of payment for legal advice to discern whether the advice was intended to benefit the trust or protect the trustee personally
• “[T]rustees ... cannot subordinate the fiduciary obligations owed to the beneficiaries to their own private interests under the guise of attorney-client privilege.”
• “In effect, the beneficiaries were the clients of [the attorney] as much as the trustees were, and perhaps more so.”

Source: CourtListener parenthetical corpus (CC0).