Deel, Inc. v. People Center, Inc. d/b/a Rippling

Summary

The Delaware Superior Court denied Deel, Inc.’s motion to disqualify Quinn Emanuel Urquhart & Sullivan from representing People Center, Inc. d/b/a Rippling. The court held that Quinn’s screening of the attorney who had consulted with Deel satisfied the applicable exception under Delaware Rule of Professional Conduct 1.18 and that the information allegedly disclosed was not significantly harmful or prejudicial in the current litigation. The court also found that an in-camera review of a September 22, 2023 email supported the conclusion that the consultation concerned a different matter.

Holdings

1. Quinn Emanuel's representation of Rippling did not require disqualification under Delaware Lawyers' Rule of Professional Conduct 1.18 because the consulted attorney was timely screened from the matter, received no fees from it, and written notice of the screen was provided to Deel.
2. Deel failed to establish that the information allegedly disclosed during the September 2023 consultation was significantly harmful or prejudicial to Deel in the current action.
3. The September 22, 2023 email and the record did not establish by clear and convincing evidence either a professional-conduct violation or a threat to the legitimacy of the proceedings sufficient to warrant disqualification.

Questions Presented

1. Whether Quinn Emanuel's representation of Rippling violated Delaware Lawyers' Rule of Professional Conduct 1.18 and required disqualification because Schwartz received confidential information from Deel during a prospective-client consultation.
2. Whether the alleged information was significantly harmful or prejudicial to Deel in the current litigation.
3. Whether the ethical screen, lack of fee allocation, and written notice prevented imputation of Schwartz's alleged conflict to Quinn Emanuel.

Disposition

other