The United States Supreme Court held that the federal evidentiary attorney-client privilege survives the client's death and therefore protects an attorney's notes taken during a client meeting from discovery by a federal grand jury when the client died shortly after the meeting and the notes are sought because of their relevance to a criminal investigation conducted by the Office of Independent Counsel.
Swidler & Berlin v. United States, 118 S. Ct. 2081 (1998).
James F. Glunt,
Evidence - Attorney-Client Privilege - Survival of the Privilege after the Client's Death,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol37/iss2/11