United States v. Kovel

United States Court of Appeals for the Second Circuit

296 F.2d 918 (2d Cir. 1961)

Relevant factsFree

Kovel (defendant), a former accountant working for a tax-law firm, was subpoenaed by a grand jury investigating client Hopps for tax fraud, and asked about his communications with Hopps. Kovel invoked the attorney-client privilege and refused to testify, and the district court held him in contempt.

IssueFree

Whether the attorney-client privilege can apply to communications made to non-attorneys.

Holding & reasoning

The court resolved the question by applying the controlling rule to the facts and explaining precisely why the outcome followed. Its reasoning ties the doctrine to the record so you can reproduce the analysis on an exam.

Procedural history, concurrence & dissent

This section traces the case from the trial court through appeal and lays out how each opinion lands. Separate writings sharpen the majority's limits and flag the arguments most likely to resurface in class.

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