A. v. B.
726 A.2d 924

Facts:
A husband and wife retained a law firm, Hill Wallack, to assist them with planning their estates. The husband had a child with another woman, who used the same firm for her suit against the husband. The conflict went unnoticed because of a clerical error. When it was discovered, the firm told the husband that it had a duty to inform the wife of the illegitimate child.

  • The husband then sued to prevent disclosure.

Issue:
Whether a law firm may disclose confidential information of one co-client with another co-client.

Holding:
Yes.

Reasoning:

  • The husband’s deliberate omission of the existence of his illegitimate child constitutes a fraud on his wife as the child could affect the distribution of the wife’s estate.
  • “When discussing their respective estates with the firm, the husband and wife reasonably could expect that each would disclose information material to the distribution of their estates, including the existence of children who are contingent residuary beneficiaries. The husband breached that duty.”