Morin v. Maine Education Ass'n

Majority: SAUFLEY, C.J., and LEVY, SILVER, MEAD, and GORMAN, JJ.

Concurrence: SILVER, J.

Dissent: ALEXANDER, J.

GORMAN, J.

[¶ 1] Maine Education Association appeals from an interlocutory order entered in the Superior Court (Kennebec County, Jabar, J.) disqualifying its counsel in connection with an employment discrimination action filed by Joan M. Morin. The Association contends that the court exceeded its discretion in disqualifying both counsel and their law firm. We agree, and vacate the judgment.

I. FACTS AND PROCEDURE

[¶ 2] The Association has employed Morin as a labor advocate, and later as a board member, since 1996. In January of 2006, she reported to her immediate supervisor that she was experiencing a hostile and discriminatory work environment. The Association hired the law firm of Bredhoff & Kaiser, P.L.L.C. to investigate Morin’s complaints.

[¶ 8] Attorney Todd Edelman at Bred-hoff & Kaiser conducted the investigation of Morin’s allegations, which included an interview with Morin. Edelman informed Morin that he was hired by the Association to conduct an “independent investigation” and that he did not represent the Associa*1099tion. Morin understood, however, that Edelman did not represent her, and in fact, Morin’s own attorney was present during the entire proceeding.

[¶ 4] Morin testified that Edelman represented to her that her statements made during the interview would remain confidential and would not be shared with the Association. Morin’s attorney testified that she would have been more “guarded” during the interview if she had known that Bredhoff & Kaiser might later represent the Association, and that she would not have offered her opinion to Edelman as to litigation strategy or settlement terms. Edelman testified, in contrast, that he explained to Morin that the details of his investigation would remain confidential “to the extent that’s practical, given the investigation, or the extent consistent with the ... pursuit of the investigation,” but that he would describe the nature of Morin’s complaint to the Association. After concluding his investigation, Edelman substantiated Morin’s allegations of discrimination.

[¶ 5] In 2007, Morin filed a complaint against the Association in the Superior Court alleging gender discrimination leading to a hostile work environment, retaliatory discrimination, intentional infliction of emotional distress, and negligent supervision. Two other attorneys from Bredhoff & Kaiser, W. Gary Kohlman and Joshua B. Shiffrin, represented the Association on a pro hac vice basis in the litigation instituted by Morin. Edelman had no role in representing the Association on Morin’s complaint.

[¶ 6] Morin moved to disqualify Kohlman, Shiffrin, and the entire law firm of Bredhoff & Kaiser on the grounds that Edelman misrepresented his role in the investigation, and would likely be called as a witness in the litigation. Following a testimonial hearing, the court granted Morin’s motion to disqualify, and denied the Association’s request for further findings. See M.R. Civ. P. 52(a). The Association timely appealed.1

II. DISCUSSION

[¶ 7] The Association challenges the court’s disqualification of Bredhoff & Kaiser and its attorneys, Kohlman and Shiffrin.2 Our review of orders granting or denying motions to disqualify counsel is “highly deferential,” and we will not disturb an order disqualifying counsel “if the record reveals any sound basis” for the trial court’s decision. Estate of Markheim v. Markheim, 2008 ME 138, ¶ 27, 957 A.2d 56, 62; Casco N. Bank v. JBI Assocs., 667 A.2d 856, 859 (Me.1995) (quotation marks omitted). We review the factual findings underlying such orders for clear error. Estate of Markheim, 2008 ME 138, ¶ 27, 957 A.2d at 62.

[¶ 8] We review such orders, however, mindful that motions for disqualification are “capable of being abused for tactical purposes, and ... justifiably wary of this type of strategic maneuvering.” Casco N. Bank, 667 A.2d at 859. Disqualification could provide the moving party with “a brief, tactical advantage, a result that *1100would debase the rules of professional conduct and subvert, not advance, the public interest they serve.” Id. at 859 (quotation marks omitted).

[¶ 9] To guard against such abuse, we have said that disqualification is appropriate only when the moving party produces evidence supporting two findings. First, disqualification must “serve the purposes supporting the ethical rules.” Id. at 859. A party moving to disqualify an attorney has the burden of demonstrating more than mere speculation that an ethics violation has occurred; she must establish in the record that continued representation of the nonmoving party by that party’s chosen attorney results in an affirmative violation of a particular ethical rule. See id. Further, even if an ethical violation is established, whether disqualification of that attorney may be imputed to the attorney’s entire law firm depends on which ethical violation is found to have occurred.

[¶ 10] Second, we require a showing that continued representation by the attorney would result in actual prejudice to the party seeking that attorney’s disqualification. See Adam v. Macdonald Page & Co., 644 A.2d 461, 464-65 (Me.1994). As we stated in Adam, courts will not assume the existence of prejudice to the moving party just by the mere fact that an ethical violation was committed, even when that ethical violation involves confidential communications. Id. A mere general allegation that the attorney has some confidential and relevant information he gathered in the previous relationship will not support disqualification. See id. Rather, the moving party must point to the specific, identifiable harm she will suffer in the litigation by opposing counsel’s continued representation. Indeed, to allow disqualification with proof of anything less than such actual prejudice would be to invite movants to employ this “obvious vehicle for abuse.” Id. at 464.

[¶ 11] Moreover, if the moving party produces evidence of both an ethical violation and actual prejudice, any court order disqualifying the attorney must include express findings of that ethical violation and resulting prejudice. In the absence of such findings, we will uphold an attorney disqualification only if both the ethical violation and the prejudice to be suffered are obvious from the record.

[¶ 12] In the instant matter, we first address the requirement of actual prejudice. Morin generally asserted that she would have been more “guarded” during her interview with Edelman, and that she disclosed to Edelman litigation and settlement strategy that she would not otherwise have shared with him had she known that Bredhoff & Kaiser would represent the Association in subsequent litigation. As a matter of law, this evidence is insufficient to establish the actual prejudice necessary to support a disqualification order. Even when viewing the disqualification evidence in the light most favorable to Morin, as the prevailing party, see In re Cyr, 2005 ME 61, ¶ 16, 873 A.2d 355, 361, Morin failed to point to any particular prejudice she has suffered or will suffer and, contrary to the dissent’s assertions, the court made no such finding of actual prejudice.

[¶ 13] We cannot uphold the disqualification of an attorney in the absence of any finding of actual prejudice to Morin by Bredhoff & Kaiser’s representation of the Association when the prejudice she asserts is not obvious from the record.3 Because *1101we conclude that the record does not support a finding of actual prejudice to Morin, we need not address the sufficiency of the evidence supporting a finding that Edel-man committed any ethical violation justifying disqualification, or whether any such disqualification could be imputed to the law firm of Bredhoff & Kaiser.

The entry is:

Judgment vacated and remanded for further proceedings.

. Although interlocutory, we consider the Association's appeal on its merits pursuant to the death knell exception to the final judgment rule. See Fiber Materials, Inc. v. Subilia, 2009 ME 71, ¶¶ 20-21, 974 A.2d 918, 926 (‘‘[W]e have routinely held that an order granting a motion to disqualify an attorney is immediately appealable" because "disqualifying an attorney involves a disadvantage and expense that cannot be remedied after the conclusion of the case.” (quotation marks and emphasis omitted)); see also Hurley v. Hurley, 2007 ME 65, ¶ 6, 923 A.2d 908, 910.

. Attorney Edelman is no longer associated with Bredhoff & Kaiser.

. At oral argument, counsel for the Association acknowledged that an employer's use of the same attorneys or law firm to both complete an internal ''independent” investigation *1101of an employee's allegations, and to represent the employer in any subsequent litigation with that employee, should include a clear explanation to the employee of the firm's dual role.