Court of Appeal holds that attorney bills transmitted to clients are confidential communications protected by the attorney client privilege

County of Los Angeles v. Superior Court (ACLU) (2015) 235 Cal.App.4th 1154 (California Court of Appeal, Second Appellate District, Division Three) [published]. The ACLU, along with an individual, made a Public Records Act request to the County of Los Angeles, seeking copies of billing statements sent to the County by attorneys defending the County in pending litigation. After the County refused the request and a trial court ordered the statements to be disclosed, GMSR filed a writ petition on behalf of the County, arguing, among other grounds, that the billing statements were confidential communications between the County and its attorneys and hence protected by the attorney client privilege. In a case of first impression, a unanimous panel agreed, holding that attorney billing statements are confidential communications within the meaning of Evidence Code section 952 and therefore subject to the attorney client privilege, thus barring production under the Public Records Act.