Recent State Decisions

April 2001

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California Court of Appeal Declines Automatic Disqualification of Attorney Whose Former Firm had Represented Adversary in Related Environmental Matters
Daphne v. Aerojet-General Corporation

A California appellate court has refused to automatically disqualify an attorney from being adverse to a client of the attorney's former firm, even where the new environmental case was substantially related to the former representation, in the absence of evidence that confidential information material to the current representation would normally have been imparted to the attorney during his tenure at the old firm.