Williams v. District of Columbia

Christina Conyers Williams (plaintiff) sued the District of Columbia (defendant) under the Whistleblower Protection Act. During discovery in 2008 the District produced a termination-recommendation packet that included a privileged email involving its Deputy General Counsel about Williams's proposed firing. Months later the District wrote demanding the email's return and barring its use; Williams never responded, and the District did nothing further for over two and a half years. When Williams listed the email as a trial exhibit in July 2011, the District moved to exclude it.

Whether inadvertent disclosure of a privileged document waives the attorney-client privilege where the holder fails to take reasonable steps to prevent the disclosure and to remedy it.