Welfare Rights Organization v. Crisan

RICHARDSON, J.

I respectfully dissent from the majority’s recognition of a novel evidentiary privilege protecting communications between welfare claimants and nonattorneys authorized to represent them at administrative fair hearings. As the majority acknowledges (ante, p. 769), such creation of a new *773privilege directly contravenes well established authority in this state limiting evidentiary privileges to those set forth in our statutes and expressly forbidding the judicial formulation of additional privileges even for what are perceived to be sound policy reasons. In my view, the well-reasoned opinion of Presiding Justice Puglia of the Court of Appeal, which follows with appropriate deletions and insertions,* correctly disposes of plaintiffs’ assertion of the heretofore nonexistent privilege:

I

We begin our analysis with the Evidence Code provisions relating to privileges. The general rule of admissibility is stated in section 911 as follows: “Except as otherwise provided by statute: [f] (a) No person has a privilege to refuse to be a witness. [1] (b) No person has a privilege to refuse to disclose any matter or to refuse to produce any writing, object, or other thing. [1] (c) No person has a privilege that another shall not be a witness or shall not disclose any matter or shall not produce any writing, object, or other thing.” The foregoing rule applies to administrative proceedings such as the AFDC hearing in question. (Evid. Code, § 901.)

The communications here do not come within any of the particular privileges enumerated in the Evidence Code. (See §§ 930-1060.) Although the lay-authorized representative’s functions are similar to those of an attorney in performing services for a client, the lay representative’s communications with clients do not come within the lawyer-client privilege. Evidence Code section 950 specifically defines “lawyer” to mean “a person authorized, or reasonably believed by the client to be authorized, to practice law in any state or nation.” Obviously, a lay advocate is not authorized to practice law. (See Bus. & Prof. Code, § 6060 et seq.) [Nor do plaintiffs assert that they were misled into “reasonably” believing that their lay representative was so authorized.]

It is well settled that the provisions in the Evidence Code relating to privilege are exclusive, supplanting any privileges previously available at common law; the courts are not free to modify them or create new privileges as a matter of judicial policy. (Evid. Code, § 12, subd. (c); Valley Bank of Nevada v. Superior Court (1975) 15 Cal.3d 652, 656 [125 Cal.Rptr. 553, 542 P.2d 977]; Pitchess v. Superior Court (1974) 11 Cal.3d 531, 539-540 [113 Cal.Rptr. 897, 522 P.2d 305].)

*774Even if the courts were at liberty to draw upon judicial precedent in construing the limits of the attorney-client privilege as defined in the Evidence Code (see Kaplan v. Superior Court (1971) 6 Cal.3d 150, 160-161 [98 Cal.Rptr. 649, 491 P.2d 1]), the rule in other jurisdictions has been that the “privilege does not extend to communications between a client and administrative practitioners who are not attorneys, ...” (McCormick on Evidence (2d ed. 1972) § 88, pp. 179, 180-181; 8 Wigmore on Evidence (McNaughton rev.ed. 1961) § 2300a, pp. 581-582; Annot. (1964) 96 A.L.R.2d 125, §§ 16-18; Brungger v. Smith (C.C.D. Mass. 1892) 49 Fed. 124, and United States v. United Shoe Machinery Corporation (D.Mass. 1950) 89 F.Supp. 357, 358-360 [nonattorney patent agents]; Falsone v. United States (5th Cir. 1953) 205 F.2d 734, 740-741, and United States v. Zakutansky (7th Cir. 1968) 401 F.2d 68, 70-71, cert. den. (1969) 393 U.S. 1021 [21 L.Ed.2d 565, 89 S.Ct. 628] [nonattorney accountants]; see also, Baird v. Koemer (9th Cir. 1960) 279 F.2d 623, 627.) Moreover, other jurisdictions having occasion to construe the scope of the privilege as provided by specific statute likewise have found communications to nonattorney administrative practitioners not to be privileged. (Kent Jewelry Corp. v. Kiefer (1952) 202 Misc. 778 [113 N.Y.S.2d 12, 15-17] [patent agent registered to practice before the patent office]; Hunt v. Maricopa Cty. Emp. Merit System Com’n (1980) 127 Ariz. 259 [619 P.2d 1036, 1041] [lay representative of county employee].)

Thus, plaintiffs must rely on other statutory or constitutional .authority to establish an AFDC claimant-lay representative privilege of confidentiality. (See Evid. Code, §§ 911, 230.)

II

Plaintiffs and amicus curiae first rely on federal regulations governing AFDC administrative hearings to supply the missing privilege. Thus, they assert that the phrase, “Except as otherwise provided by statute,” as contained in Evidence Code section 911 should be interpreted to embrace these federal regulatory provisions or, alternately, that the applicable federal regulations preempt any conflicting state law precluding a privilege by virtue of the supremacy clause of the United States Constitution (U.S. Const., art. VI, § 2).

The regulatory provisions upon which plaintiffs and amicus base these alternate contentions are found in 45 Code of Federal Regulations, section 205.10. They cite as controlling section 205.10(a)(3)(iii), which provides that every AFDC applicant or recipient “may be represented by an authorized representative, such as legal counsel, relative, friend, or other spokesman, or he may represent himself . . . .’’In addition, they cite language in section 205.10(a) (13)(iv) and (v) as follows: “The claimant, or his representative, shall have an adequate opportunity: ... To establish all pertinent facts and circumstances” *775and “To advance any arguments without undue interference; ...” (See similarly Welf. & Inst. Code, § 10950.) Maintaining that these provisions establish an adversary hearing system whereby the nonattorney authorized representative stands on a similar footing with legal counsel, plaintiffs argue that the right to select a lay representative and the opportunity to develop facts and advance arguments after exercising that right would be “shattered” if a representative-claimant privilege did not apply.

Similar arguments have been advanced in recent federal cases involving patent agents who practice before the United States Patent Office. In Sperry v. Florida (1963) 373 U.S. 379 [10 L.Ed.2d 428, 83 S.Ct. 1322], the United States Supreme Court reversed a Florida decision holding that a patent agent who met specified qualifications and was registered with the patent office but who was not a licensed Florida attorney could not perform patent services within the State of Florida. In reversing, the high court reasoned: Although the patent practitioner’s services constitute the unauthorized practice of law under Florida law, federal statutes and regulations which qualify both registered patent agents and attorneys to engage in certain patent activities preempt the conflicting state law; hence, the state is powerless to deny the agent a supreme right granted by federal law.

Subsequent federal cases addressing the subject of privilege for nonattorney patent agent communications in light of the Sperry decision are divided. The majority view is that there is no privilege. (Joh. A. Benckiser G.m.b.H., Chem. F. v. Hygrade Food Prod. Corp. (D.N.J. 1975) 253 F.Supp. 999; see also Duplan Corporation v. Deering Milliken, Inc. (D.S.C. 1974) 397 F.Supp. 1146, 1169.) The minority position holds that the attorney-client privilege must be made available to communications of registered patent agents in order not to frustrate the congressional scheme. (In re Ampicillin Antitrust Litigation (D.D.C. 1978) 81 F.R.D. 377, 393-394 and cases cited at p. 392.) Said the court in the Ampicillin case: “That freedom of selection, protected by the Supreme Court in Sperry, would ... be substantially impaired if as basic a protection as the attorney-client privilege were afforded to communications involving patent attorneys but not to those involving patent agents. ” (Fn. omitted; id., at p. 393.) The Ampicillin court, however, carefully limited the availability of the privilege to agents registered with the patent office and emphasized the fact that these agents are on equal footing with a patent attorney because they are subject to similar professional and ethical standards set by the patent office. (Id., at pp. 393-394, fn. 32; see also 8 Wigmore, supra, § 2300a, at p. 582.)

In the present situation there are no professional or ethical standards or licensing or registration requirements set by an appropriate administrative body which would place nonattorney representatives of AFDC claimants on a par professionally with lawyers practicing in the same setting. Instead, the federal *776regulations here permit AFDC claimants to authorize whomever they choose to act as their hearing representative. If we were to read these same federal regulations so broadly as to require the availability of privileged communications with any authorized representative, there would be no real limitation on nor clear definition of when and with whom the privilege might apply. Hence, we will not go beyond the rationale of the Ampicillin case and interpret the AFDC federal regulations, silent on the subject of privilege, nonetheless to require one.

HI

Citing Goldberg v. Kelly (1970) 397 U.S. 254 [25 L.Ed.2d 287, 90 S.Ct. 1011] and Mathews v. Eldridge (1976) 424 U.S. 319, 335 [47 L.Ed.2d 18, 33, 96 S.Ct. 893], plaintiffs assert that an AFDC claimant’s constitutional due process right to a fair hearing prior to any administrative denial or reduction in benefits also mandates the recognition of a privilege against compelled disclosure of lay representative-claimant communications. They argue that the individual claimant’s substantial interest in welfare benefits, the value of authorized representative-claimant confidentiality, and the government’s interest in protecting such confidentiality outweighs any countervailing state interests in not allowing a privilege. This argument also fails.

The Goldberg decision and its progeny were concerned with the right to be heard and accompanying procedures safeguarding that right prior to governmental curtailment of substantial individual rights. In Goldberg, the court specifically held that the interest of an eligible AFDC recipient in uninterrupted receipt of public assistance, coupled with the state’s interest that such payments not be erroneously terminated, outweighed any opposing state interest in not providing a pretermination hearing with the accompanying rights to cross-examine and confront adverse witnesses and to retain counsel. Yet the court neither held nor implied that formal evidentiary rules would be required in such a setting as a matter of due process. In fact, it specifically stated: “Informal procedures will suffice; in this context due process does not require a particular order of proof or mode of offering evidence.” (397 U.S., supra, at p. 269 [25 L.Ed.2d at p. 300].)

We have found no case where the attorney-client privilege has been associated with a constitutionally based opportunity to be heard when civil interests such as the one here are involved. [Fn. omitted.] As we have discussed, the origins of the privilege are in the common law (see 8 Wigmore, supra, § 3390, pp. 542-545), and its current status is purely statutory, existing only so far and in favor of such persons as the legislative power may declare. It necessarily follows that any analogous lay advocate-client privilege also lacks constitutional underpinnings. Merely because federal regulations permit a *777welfare applicant or recipient to authorize a lay advocate instead of an attorney as a hearing representative, procedural due process does not require that a privilege be available for communications transmitted within the course of that relationship. There is no unfairness of constitutional dimension.

We are neither unaware of nor insensitive to the policy considerations which militate in favor of extending the attorney-client privilege to the lay representative-claimant relationship in the administrative fair hearing context. However, we are not at liberty to say what should be with regard to the privilege of confidentiality. (See Valley Bank of Nevada v. Superior Court, supra, 15 Cal.3d at p. 656; Pitchess v. Superior Court, supra, 11 Cal.3d at pp. 539-540.) As we have seen, it is now the prerogative of the Legislature or Congress to make such policy decisions and to delineate what shall be the nature and scope of the attorney-client privilege. In the future, that legislative power may well delimit the availability of a privilege to lay advocates having some professional and formally supervised status. (See 8 Wigmore, supra, § 2300a, p. 582.) There is no evidence that the lay representative here would so qualify. As aptly stated by the trial court judge: “One is reminded that the original definition of a ‘psychotherapist’ as set forth in Evidence Code section 1010 was amended in 1970 to include clinical social workers and school psychologists and again amended in 1972 to include marriage, family and child counselors. These professionals probably felt that their communications were confidential but it took legislative action to accord the privilege which, undoubtedly, sound policy dictated.” [End of Court of Appeal opinion.]

In my view, the majority errs in jettisoning the foregoing straightforward analysis of plaintiffs’ claims. Instead, my colleagues wending their tortuous way around the statutory and decisional obstacles create, by judicial fiat, a new nonstatutory evidentiary privilege. While their praise of the attorney-client privilege (see ante, pp. 770-771, and fn. 2) is commendable, their failure to observe its limitation and to restrict its availability to attorneys and their clients, is not. A comparable new privilege for communications between nonattorneys and those whom they represent should not be fashioned judicially from supposed implication alone, but should await precise legislative expression.

I would affirm the judgment.

Brackets together, in this manner [], are used to indicate deletions from the opinion of the Court of Appeal; brackets enclosing material (other than the editor’s parallel citations) are, unless otherwise indicated, used to denote insertions or additions by this court. (Estate of McDill (1975) 14 Cal.3d 831, 834 [122 Cal.Rptr. 754, 537 P.2d 874].)