USING POLICY TO RESOLVE THE CIRCUIT SPLIT OVER THE CRIME-FRAUD EXCEPTION TO THE ATTORNEYCLIENT PRIVILEGE.

The article discusses the need for the U.S. Supreme Court to clarify the issues on the use of crime-fraud exception to the attorney-client privilege and how policy can be utilized to resolve the contrasting opinions of federal circuit courts on the issues. Topics include the ruling by the court in the case U.S. v. Zolin, the system of rules based on locations, and the common law privilege of confidential communications between attorneys and their clients.