Litigation - Notes

Litigation and the Adversary System

The Adversary System: Context of Litigation

  • Litigation operates within an adversary system.
  • This system is based on the clash of opposing parties.
  • The clash is regulated by rules.
  • The system is presumed to yield good results if everyone adheres to the rules.

Deciding to Litigate and Frivolous Litigation

  • The decision to engage in litigation requires careful consideration.
  • Frivolous litigation is a concern regulated by rules of professional conduct and civil procedure.
  • Understand the principles behind rules preventing frivolous litigation.
  • Distinguish between frivolous litigation and litigation instituted for improper motives.
  • Lawyers may face disciplinary and procedural sanctions for either.

Underlying Values of the Adversary System

  • Consider the letter to the editor about William Kunstler (a prominent civil rights lawyer). Research Kunstler if you're unfamiliar.
  • The letter questions the American legal system's effectiveness and concept of justice.
  • The author suggests the goal of a criminal trial should be to find the truth.
  • The author implies Kunstler was wrong in how he litigated for his clients.
  • However, the American justice system is based on values that don't always prioritize discovering the truth.
  • Example: motion to suppress evidence, based on values more important than truth.

The Role of Litigators: Pretrial Litigation and Discovery

  • Litigators spend most of their time on pretrial litigation, specifically discovery.
  • Most cases settle without trial.
  • The duties of lawyers in discovery are crucial.

Ethics in America: Discovery in a Product Liability Case

  • Discussion of a PBS program, Ethics in America, featuring lawyers discussing a fictional product liability case.
  • The case involves Hot Products, a company that makes space heaters (specifically, the Hot Boy model).
  • Hiram Powers, the CEO, consults with counsel about a memo from safety engineer Nelly Barnes.
  • Nelly is concerned about fires potentially caused by the Hot Boy due to a faulty shutoff mechanism when the heater tips over.
  • Fixing the issue with an emergency shutoff would significantly increase the product's price and alter the market structure.
  • Powers hasn't made a decision to shift the product because it's not clear enough a problem exists.
  • Counsel advises that the company could face liability if someone gets hurt, especially with notice from Barnes' memo.
  • Powers claims the memo is the only copy and was delivered to him directly by Nelly.
  • Another counsel suggests the CEO may get a zealous prosecutor who wants to prosecute your criminals too for some sort of reckless conduct and recommends stopping and considers a recall.
  • Discussion of whether the counsel should challenge the CEO's business decision.
  • One lawyer suggests going to the board of directors.
  • Birnbaum suggests tough decisions are made alone by Powers, showing a memorandum that includes:
    • Nelly's description of difficulties.
    • An estimate of 40 fires per year if Nelly's claims are correct.
    • Potential deaths (maybe six).
    • Estimated lawsuit settlements of $200,000 each.
    • High costs of repositioning or recalling the product.
    • Conclusion: Better to study the problem further and keep producing.
    • Note: The kind of people that use these hot boys cheap space heaters, they're not really into lawsuits that much.
  • This memo is described as a "smoking gun document" that could lead to punitive damages if discovered in civil litigation.
  • Discussion about whether to destroy the memorandum.
  • Destroying documents can be worse than finding them because juries may infer the document contained damaging information.
  • Advice given not to create memos like that in the first place.
  • Erase the document if you always override things that you've written to yourself as a general matter.
  • No law broken if the CEO destroys the memo (in any jurisdiction known).
  • Destruction of the memo can be performed tactically, but the firm will deal with the aftermath if it is discovered.
  • It is legally permissible because it's purely tactical but ethically wrong to get rid of it.
  • Judge Scalia agrees with the legality of destroying the document at this point.
  • It becomes illegal to destroy a document once it's subpoenaed or noticed in discovery.
  • A lawyer recommends only answering the asked question directly and not to volunteer and expand on answers.
  • Also, only answer if you're sure that you know the answer.

Key Questions for Further Consideration

  • At what point does a valid and reasonable defense to discovery become improper gamesmanship?
  • Where is the line between zealous advocacy and conduct prejudicial to the administration of justice?
  • Articulate the principles upon which the adversary system of litigation is based.