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This article examines recent cases that have significantly expanded the ability of law firms to claim attorney-client privilege for communications with their designated in-firm general counsel. These cases have relevance even to lawyers practicing in firms too small to warrant the appointment of an in-firm general counsel. This is because many of the earlier cases denied the privilege for communications within law firms based on adoption of a “current client” or “fiduciary” exception, and, based on the same theory, some of those earlier cases cast doubt on the availability of the privilege even with respect to communications with outside counsel. The two recent cases dealing with the in-firm privilege are RFF Family Partnership v. Burns & Levinson, 465 Mass. 702 (July 10, 2013), and St. Simons Waterfront v. Hunter, Maclean, Exley & Dunn, — S.E.2d —, 2013 WL 3475328 (Ga. July 11, 2013).

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