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Lambright v. Ryan, 698 F.3d 808, 12 Cal. Daily Op. Serv. 11,679, 2012 Daily Journal D.A.R. 14,389

Facts

In 1987, Lambright filed a federal habeas petition claiming ineffective assistance of sentencing counsel. The district court initially dismissed his claim but was later ordered to hold an evidentiary hearing. During the proceedings, a protective order was issued to safeguard certain materials, but the district court later modified this order to allow the Pima County Attorney's Office access to materials produced during the federal habeas proceeding, which Lambright contested as a violation of his privileges.

In 1987, Lambright filed a federal habeas petition claiming ineffective assistance of sentencing counsel. The district court initially dismissed his claim but was later ordered to hold an evidentiary hearing. During the proceedings, a protective order was issued to safeguard certain materials, but the district court later modified this order to allow the Pima County Attorney's Office access to materials produced during the federal habeas proceeding, which Lambright contested as a violation of his privileges.

Issue

Did the district court abuse its discretion in modifying the protective order to allow disclosure of materials that Lambright claimed were privileged?

Did the district court abuse its discretion in modifying the protective order to allow disclosure of materials that Lambright claimed were privileged?

Rule

A district court must ensure compliance with the fairness principle when permitting discovery of attorney-client materials in habeas cases and must enter appropriate orders delineating the contours of any limited waiver of privilege before the commencement of discovery.

A district court must ensure compliance with the fairness principle when permitting discovery of attorney-client materials in habeas cases and must enter appropriate orders delineating the contours of any limited waiver of privilege before the commencement of discovery.

Analysis

The Court of Appeals found that the district court's interpretation of the protective order was illogical, as it limited the order's scope to materials produced only after its issuance. The court emphasized that the protective order should cover all materials produced in the federal habeas proceeding, regardless of when they were produced. Additionally, the court noted that the district court failed to issue the protective order prior to the disclosure of privileged materials, which constituted an abuse of discretion.

The Court of Appeals found that the district court's interpretation of the protective order was illogical, as it limited the order's scope to materials produced only after its issuance. The court emphasized that the protective order should cover all materials produced in the federal habeas proceeding, regardless of when they were produced.

Conclusion

The Court of Appeals affirmed in part and vacated in part the district court's order, remanding the case for further proceedings to resolve disputes regarding which specific materials are privileged and should remain protected under the modified protective order.

The Court of Appeals affirmed in part and vacated in part the district court's order, remanding the case for further proceedings to resolve disputes regarding which specific materials are privileged and should remain protected under the modified protective order.

Who won?

Joe Leonard Lambright prevailed in part, as the Court of Appeals found that the district court abused its discretion in modifying the protective order regarding privileged materials.

Joe Leonard Lambright prevailed in part, as the Court of Appeals found that the district court abused its discretion in modifying the protective order regarding privileged materials.

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