Greyhound Corp. v. Superior Court
California Supreme Court
364 P.2d 266 (1961)
Earline Z. Clay and Leslie Randolph Clay sued Greyhound Corporation for personal injuries suffered in an accident involving a Greyhound bus. During pretrial discovery, plaintiffs moved under section 2031 of the Code of Civil Procedure for an order requiring Greyhound to produce and permit inspection, copying, or photographing of written statements taken from independent, percipient witnesses to the accident. Those statements had been gathered by Greyhound's adjusters and investigators for use by its attorneys. Greyhound opposed the motion, arguing the statements were protected by the attorney-client privilege and by the attorney work-product doctrine recognized in the federal case Hickman v. Taylor.
Whether disclosure of information in discovery is a matter of right under California law unless statutory or public-policy considerations clearly prohibit it.