Ralls v. United States
United States Court of Appeals for the Ninth Circuit
52 F.3d 223 (1995)
Defense attorney Ralls (defendant, in the subpoena proceeding) was retained by a third party to represent Bonette at an initial appearance and detention hearing on drug charges; a grand jury subpoena sought the fee-payer's identity, payment details, and the substance of Ralls's conversations with the fee-payer, and the district court ordered disclosure of the identity and payment details while extending privilege only to the conversations, holding Ralls in contempt when he refused to comply with the disclosure order.
Whether attorney-client privilege applies to information related to fee agreements when disclosure would reveal information customarily regarded as privileged communications.