Bradford Lund v. Hon. Myers

OPINION

BRUTINEL, Justice.

¶ 1 We address when a trial court, in deciding issues of privilege and waiver, may review in camera allegedly privileged documents that were inadvertently disclosed. 1 We hold that before reviewing a particular document, a trial court must first determine that in camera review is necessary to resolve the privilege claim.

I

¶2 This litigation began in 2009, when relatives of Bradford Lund (the real parties in interest in this case, collectively, “Miller”) sought the appointment of a guardian and conservator to manage Bradford’s assets. Bradford, his father, and his…