Morin v. Maine Education Ass'n

ALEXANDER, J.,

dissenting.

[¶ 21] I respectfully dissent. The trial court, after a contested, testimonial hearing, found that Joan Morin and her attorney were “credible” and disqualified counsel. The record before the trial court, while including disputes as to the facts, supports the conclusions that: (1) statements by the Maine Education Association’s retained attorney misled Morin into believing that he was an independent investigator, conducting an impartial investigation; (2) as a result of the misleading statements, Morin disclosed to the investigator confidential information and litigation objectives that she would not have otherwise disclosed; (3) the Association’s attorney disclosed the information provided by Morin and his notes of the meeting to co-counsel for the Association, violating a commitment to Morin that the information Morin provided would not be disclosed to the Association; and (4) the Association’s attorney, having obtained this sensitive information, may have made himself a necessary witness in the case.

[¶ 22] Faced with this record, and its credibility determination, the Superior Court acted appropriately. We have said, on several occasions, that our review of trial court orders granting or denying motions to disqualify counsel is “highly deferential,” and that we will not disturb an order disqualifying counsel “if the record reveals any sound basis” for the trial court’s action. Estate of Markheim v. Markheim, 2008 ME 138, ¶27, 957 A.2d *110356, 62; Hurley v. Hurley, 2007 ME 65, ¶ 8, 923 A.2d 908, 910; Casco N. Bank v. JBI Assocs., 667 A.2d 856, 859 (Me.1995). “Any ‘doubts should be resolved in favor of disqualification.’ ” Hurley, 2007 ME 65, ¶ 8, 923 A.2d at 910 (quoting Casco N. Bank, 667 A.2d at 859).

[¶ 23] The trial court’s findings and conclusions support the view that the Association’s attorney misrepresented his role as an independent, impartial investigator in violation of M.R. Prof. Conduct 8.4(c) and M. Bar R. 3.2(f)(3) (2008). As a result of this misrepresentation, the Association’s attorney obtained and turned over to co-counsel confidential information and notes about Morin’s view of the facts and litigation strategy. The trial court correctly concluded that the possession of such confidential information obtained through misrepresentation by an attorney or firm representing an adverse party is grounds for disqualification. See Estate of Markheim, 2008 ME 138, ¶¶ 20-21, 26-29, 957 A.2d at 61-62; Hurley, 2007 ME 65, ¶¶ 7, 20, 923 A.2d at 910, 912.

[¶ 24] As a separate ground for disqualification, the trial court correctly concluded that the Association’s attorney placed himself in a position where he may be a necessary witness at trial for either Morin or the Association. The attorney may likely be required to testify regarding statements made by Morin during his investigation. In the circumstances, M.R. Prof. Conduct 3.7(a), which will govern the trial, and M. Bar R. 3.4(g)(l)(ii) (2008), which applied when the events at issue here occurred, bar continued representation of the Association by its investigating counsel. This bar on continued representation extends to the firm because the attorney-investigator’s actions were undertaken as part of the firm’s representation of the Association, and the attorney willingly shared the information he gained and his notes within the firm.

[¶ 25] On the record presented, with two separate grounds for disqualification demonstrated, the Superior Court had little choice but to disqualify the investigating attorney and his firm.

[¶ 26] The Court vacates the disqualification because it concludes that Morin has failed to demonstrate any prejudice to her from the actions of the Association’s attorney.

[¶ 27] It is difficult to predict how improperly obtained information, given in confidence, might be used or misused at trial. For that reason, opposing counsel’s possession of confidential information that may be relevant and material and that was improperly obtained from the opposing party is the basis for disqualification, without regard to prediction of how such information might be used at trial, or in trial strategy planning. Prejudice is — or should be — presumed from the possession of relevant confidential information that has been improperly obtained.

[¶ 28] As we indicated in Hurley, we look to the relevance of the confidential information at issue in deciding disqualification. 2007 ME 65, ¶¶9, 17, 923 A.2d at 910, 912. That relevant information may include facts about the case, and it may also include information, such as a person’s litigation objectives or observations of a person’s capacity to handle stress, that may inform an opponent’s litigation strategy. Id.; Adam v. MacDonald Page & Co., 644 A.2d 461, 464 (Me.1994). Here, the improperly obtained information was relevant to the facts of the case and could be used to inform the opponent’s litigation strategy. With those points demonstrated, no further proof or finding of prejudice was required. The record, with the credibility determination made by the trial court, supports the trial court’s findings *1104and conclusions and the disqualification remedy it ordered.

[¶ 29] I would affirm the disqualification order.