Ibn Williams v. Coppin State University, et al.

Summary

The court addresses Plaintiff Ibn Williams’s motion to compel production of a memorandum concerning a Title IX claim that Defendants withheld based on attorney-client privilege and work-product protection. Finding a sufficient factual basis for the asserted protections but also indications that the memorandum may contain severable nonprivileged material or relate to a disclosed investigative summary, the court orders Defendants to submit the memorandum for in camera review.

Holdings

1. Defendants made a sufficient factual showing to support a good-faith belief that in camera review of the Title IX Legal Analysis may reveal evidence establishing the asserted attorney-client privilege or work-product protection.
2. Because plaintiff identified evidence suggesting that the two Ogletree documents could constitute a single analysis or contain severable nonprivileged material, the court ordered defendants to submit the Title IX Legal Analysis for in camera review before determining whether any portion should be disclosed.

Questions Presented

1. Whether defendants established a sufficient factual basis for the court to conduct in camera review of the withheld Title IX Legal Analysis claimed to be protected by attorney-client privilege and the work-product doctrine.
2. Whether plaintiff's evidence created a good-faith basis to determine through in camera review whether the document contained severable nonprivileged material or was part of a single analysis whose subject matter may have been disclosed through CSU's production and adoption of the Investigative Summary.

Disposition

other