The Pennsylvania Superior Court recently has had its struggles and challenges with attorney-client privilege issues. Those struggles continue with Corey v. Wilkes Barre Hospital, 2019 PA Super 288, (Sept. 23, 2019).

The result in Corey is likely the result of a bad facts/bad law dynamic. The bad facts are that Lesley Corey had decided to file for a divorce from her husband, Joseph Corey. She hired a lawyer who filed a divorce complaint on her behalf. The complaint stated that the Corey marriage was irretrievably broken with no hope of reconciliation. Six months later, while the divorce proceedings were still pending, Joseph Corey died.