In United States v. Zolin, 491 U.S. 554 (1989), the court granted certiorari to determine whether the attorney-client privilege crime-fraud exception applies to a case arising out of the Internal Revenue Service (IRS) investigation of the tax returns of L. Ron Hubbard, founder of the Church of Scientology.

The specific question presented was whether the crime-fraud exception must be established by “independent evidence” (i.e., without reference to the content of the contested communications themselves) or, alternatively, whether the applicability of the exception can be resolved by an in camera inspection of the allegedly privileged material.