Duquesne Law Review


The Supreme Court of the United States, in a unanimous decision, has held that the control group test for determining the applicability of the attorney-client privilege in the corporate context is overly restrictive and that any future application of the privilege must be on a case by case basis. The Court also held that the work product doctrine is applicable to administrative summonses.

Upjohn Co. v. United States, 449 U.S. 383 (1981).

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