Client identities do not enjoy blanket attorney-client privilege protection under Pennsylvania’s Right-to-Know Law, the state Supreme Court has ruled.

The court set a fact-specific standard in determining that client identities are typically not privileged unless they would be coupled with information about what type of work the attorney has done on behalf of the client that, when disclosed together, would essentially disclose attorney-client communications. The Supreme Court determined, however, that previous disclosure that the attorney is representing a client in a grand jury investigation is not enough to protect the identity of the client.