CONFLICTS ISSUES FOR GOVERNMENT...

CONFLICTS ISSUES FOR GOVERNMENT LAWYERS

"Lawyers are an integral and vitally important part of our system ofjustice. It is

they who prepare and put their clients' cases before courts and tribunals. In

preparing for the hearing of a contentious matter, a client will often be required to

reveal to the lawyer retained highly confidential information. The client's most

secret devices and desires, the client's most frightening fears will often, of

necessity, be revealed. The client must be secure in the knowledge that the lawyer

will neither disclose nor take advantage of these revelations." 1

"r adopt, in this respect, the notion of a 'conflict' in § 121 of the Restatement

Third, The Law Governing Lawyers (2000), vol. 2, at pp. 244-45, as a 'substantial

risk that the lawyer's representation of the client would be materially and

adversely affected by the lawyer's own interests or by the lawyer's duties to

another current client, a former client, or a third person' ." 2

"[r]t is the firm not just the individual lawyer, that owes a fiduciary duty to its

clients, and a bright line is required. The bright line is provided by the general

rule that a lawyer may not represent one client whose interests are directly

adverse to the immediate interests of another current client - even if the two

mandates are unrelated - unless both clients consent after receiving full

disclosure (and preferably independent legal advice), and the lawyer reasonably

believes that he or she is able to represent each client without adversely affecting

the other." 3

ETHICS AND PROFESSIONAL RESPONSIBILITY

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INTRODUCTION

In March of2007, the Canadian Bar Association established its Task Force on Conflicts of

Interest to "consider a more practical approach to managing conflicts for clients and the

profession and to develop useful model materials for lawyers". 4 While the task force was

comprised of an impressive contingent of lawyers from a variety of backgrounds and from all

regions of the country, there was initially no one among the membership who represented the

perspective of the public sector lawyer. In October of2007, I was invited to join the task force

for the purpose ofproviding that perspective.

The task force published a consultation paper in October of2007. The paper provided a clear

and succinct summary of the law related to the lawyer's dual duties of confidentiality and

loyalty, set out the preliminary views of the task force with respect to several key questions and

invited responses. The responses received played a significant role in shaping the collective

thinking of the task force that will be represented in its final report.

One of my main tasks was to examine each element of the work ofthe task force with a specific

question in mind: do the responsibilities of a government lawyer, or the responsibilities of a

government as client, lead to different conclusions on questions related to conflicts? By and

large, the answer was no. However, there are factors that make government lawyers and

government clients different from their counterparts in the private sector when considered in the

context of conflicts of interest, and these factors, at minimum, colour how we view certain

conflicts issues.

GOVERNMENTS ARE BIG

The sheer size of government institutions and government law offices sets them apart from most

clients and most law firms. No doubt large clients with correspondingly large needs for legal

services and large law offices see more conflicts issues. Arguably, that just goes with the


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territory, and is matched by the scale of the resources available to deal with the issues. However,

size presents particular potential problems related to the duty of loyalty.

The so-called bright line rule related to loyalty set out in Neil is troublesome in its potential

breadth of application. Governments as clients are at risk in one particular situation. It

sometimes goes unnoticed that the court would require consent from both clients before a law

firm would be allowed to act both for and against a client, even in an unrelated matter. We

understand that a law firm representing a government in one matter might have to obtain the

government's consent before acting for another client against the government in a different and

unrelated matter (subject to the discussion on implied consent below). Less well understood is

the requirement that a law firm representing a client against the government in one matter might

be required to obtain that client's consent before taking on a different and unrelated matter on

behalf of the government against a third client. Put more bluntly, once a law firm begins acting

for a client against the government, it may be precluded from acting for the government in any

other matter, unless the first client is prepared to allow it.

In some instances, this fact situation could engage the law firm's duty ofloyalty in a meaningful

way. A client might choose a law firm on the understanding that the firm does not act for the

government. In that case, the client might reasonably feel betrayed if the firm takes on a

government file, even though it is unrelated. In most cases, however, it will not occur to the

client to consider this possibility.

As a potential problem, this seems big. At any given time, almost every law firm of significant

size would have a client with a dispute of some nature with the government. In theory, the

government would be precluded from retaining any of those firms without the consent of their

respective clients. This could be a major problem for governments. Although governments

receive most of their legal services from lawyers inside the government, they also rely heavily on

private law firms.


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Having identified this issue, it is not clear that it is currently leads to problems. However, it may

be that, whether consciously or not, law firms simply do not apply the rule in the broad manner

set out in Neil.

An appropriate retainer letter establishing the terms of the law firm's engagement of its other

client might help to address the issue. The CBA task force will be making recommendations

with respect to the use of retainer letters.

The court in Neil may have recognized another way in which the sheer size of governments and

their corresponding consumption of legal services deserve special consideration:

In exceptional cases, consent ofthe client may be inferred. For example,

governments generally accept that private practitioners who do their civil or

criminal work will act against them in unrelated matters, and a contrary position

in a particular case may, depending on the circumstances, be seen as tactical

rather than principled. Chartered banks and entities that could be described as

professional litigants may have a similarly broad-minded attitude where the

matters are sufficiently unrelated that there is no danger of confidential

information being abused. These exceptional cases are explained by the notion of

informed consent, express or implied.5

Perhaps the court felt that governments, along with banks and "professional litigants", were too

jaded by their regular contact with lawyers and court rooms to cling to any formal notion of

loyalty.

Governments likely do not, by and large, take issue with the court's suggestion that they

impliedly consent in the usual course of retaining a law firm. However, this is on the

understanding that the circumstances of the retainer or, even more clearly, the government's

express withdrawal of that implied consent can operate to remove it. Government clients are not

so much concerned with loyalty in the sense central to the imposition of the duty of loyalty, but


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rather the use of information a law firm gains through representation of the government that,

while not strictly confidential and therefore not sufficient to invoke the duty of confidentiality,

may give what the government perceives to be an inappropriate advantage to the law firm's other

client in the matter in which the government is adverse in interest.

GOVERNMENT LAWYERS SERVE ONE CLIENT

While there may be debate in some circles with respect to the question of who is the government

lawyer's client, the broad consensus among public lawyers in Canada and the governments they

represent is that their client is the government that employs or retains them, rather than the

individual officials of that government or the public, or public interest, at large.

The discussion is complicated by the fact that government lawyers often act for statutory

functionaries (e.g. the office of public guardian or public trustee) who are part of the government

or for government entities that are created separate from the government proper (e.g. boards,

commissions and Crown corporations). These entities are not merely organizational units of the

government, as are ministries or departments. Therefore, there are instances where a government

law office acts for two government clients in the same matter and where it is necessary to be

aware ofpotential conflicts.

Even where government lawyers act under the authority of the Attorney General, they should be

mindful of the particular authority they are exercising. This is illustrated most frequently in

relation to the exercise of the Attorney General's prosecutorial responsibilities alongside other

responsibilities that arise in relation to a prosecution. The Saskatchewan case ofR. v. Kimmie 6

serves as an example, where the Attorney General carried out his prosecutorial function through

a prosecutor from the Public Prosecutions Division of his department while appearing through a

lawyer from the Public Law Division to address issues related to court appointed counsel.? In

Saskatchewan, representation for the government in applications for the production of personal

information in the possession of the government pursuant to s. 278.3 of the Criminal Code would

also normally be handled by a lawyer other than the prosecutor.


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While it is normally clear that government lawyers act solely for the government that employs or

retains them, they routinely have contact with members of the public. These encounters do not

create a solicitor-client relationship, but a member of the public dealing with a government

lawyer might occasionally and erroneously conclude that the relationship exists. Government

lawyers are generally aware ofthis possibility, and are accustomed to reminding members of the

public that any assistance they render is not provided within a solicitor-client relationship and

that members of the public must obtain any legal advice they require from their own independent

counsel.

Government lawyers rarely, if ever, provide formal representation for two government clients

adverse in interest. In such cases, one or both clients is passed to a private law firm or to two

law firms. While it may seem strange to most Canadian lawyers and judges, it is interesting to

note that Neil likely lends support to the notion that one law firm may represent opposing clients

ifboth clients consent. Saskatchewan's Legal Aid Commission implements such a policy by

allowing its various offices to represent opposing clients pursuant to the express authority

granted by s. 31 of The Legal Aid Act 8:

A solicitor does not commit a breach ofa by-law of the Law Society of

Saskatchewan relating to conflict of interest by reason only of advising or

representing a person in a dispute where a party opposite in interest in the dispute

is being advised or represented by a solicitor providing his or her services under

the Act in another area.

In this specific statutorily based instance, consent from the clients is not required.

Of course, there are reasons beyond the rules relating to conflicts for a law firm to be concerned

about representing opposing sides in a conflict,even where the clients wish that, and it's unlikely

the practice will ever become commonplace. However, government lawyers commonly do take

sides, in an informal sense, in the internal discussions and disagreements that inevitably arise in a


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large and complex organization. This is normally considered a healthy aspect of the decision

making processes, provided lawyers and other government officials understand that their

responsibilities are ultimately to the executive government as a whole.

GOVERNMENTS AND GOVERNMENT LAWYERS HAVE SPECIAL

RESPONSIBILITIES

Government institutions tend to be large organizations with correspondingly large appetites for

legal services, which are provided by both in-house and outside counsel. They need to be able to

meet those needs and, therefore, require access to quality legal services from the most

appropriate sources. In this sense, they are much like other large corporate clients.

However, government institutions are not like all other large corporate clients in at least two

meaningful ways. Governments have significant responsibilities related to the administration of

justice and they serve the public interest generally.

Similarly, government lawyers are in many ways like all other lawyers. Like all lawyers, they

have professional responsibilities and personal interests related to their practice. But, because of

their roles relative to their government clients, they share the responsibilities of their government

clients related to the administration ofjustice and the public interest.

These legally imposed mandates and the responsibility to serve the public interest might

arguably justify special consideration in the context of conflicts rules. When the balancing of

interests inherent in these principles takes place, additional weight might be placed on the need

to ensure adequate and appropriate legal resources to carry out governmental responsibilities.

But, this may already occur to some degree.

The law offices of the federal, provincial and territorial governments acquire their authority

pursuant to the Justice and Attorney General statutes in eachjurisdiction.9 Prosecution services

exercise powers found in the Criminal Code. The lawyers in these offices do not choose their


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clients. They serve the client they are mandated to serve pursuant to these statutes. Attorneys

General carry out few of these responsibilities directly. That task is assigned to government

lawyers who derive their authority and their responsibilities through the Attorney General.

While there are differences in the Justice or Attorney General legislation in each jurisdiction,

there are many similarities. The statutes typically include provisions making the Attorney

General responsible to:

- see that the administration of public affairs is in accordance with the law;

- superintend all matters connected with the administration ofjustice in the

applicable jurisdiction;

- perform the common law and constitutional powers belonging historically to the

Attorney General;

- advise the government on all matters of law connected with legislative

enactments and upon all matters of law referred to him or her by the

government;

- advise the government on all matters of a legislative nature and superintend all

government measures of a legislative nature;

- advise the heads of the ministries and agencies of government on all matters of

law connected with those ministries and agencies; and

- regulate and conduct all litigation for and against the Crown.

As mentioned earlier, Attorneys General also bear responsibility for criminal prosecutions

pursuant to the Criminal Code.


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There is a slowly emerging body of case law dealing specifically with the application of conflicts

rules in the government setting. Perhaps the most significant is the Manitoba Court ofAppeal's

decision in R. v. D. (WR.). 10 There the complainant in a criminal prosecution was also a

plaintiff in a civil action against the government arising out of the same alleged incidents. The

accused argued successfully before the Queen's Bench that the Attorney General was in a

conflict of interest position. In granting the Crown's appeal, Huband l.A. stated:

Defence counsel invites us to draw an analogy to the situation which faces a

private law firm whose members have accepted both sides of a civil case, and

who must send their clients elsewhere.

The position of the Attorney General is not analogous to that ofa private law firm

which has encountered a conflict of interest problem. In the criminal proceeding

against the accused, [the complainant] is simply a witness. There is no solicitor

client relationship giving rise to confidentiality. In the civil proceeding [the

complainant] is an adverse party, and again there is no solicitor-client relationship

where confidentiality is involved.

The Attorney General is in a unique position, quite unlike that of a member of the

private Bar. She is responsible for the prosecution of criminal cases within this

jurisdiction. She also represents the Government ofManitoba for forensic

purposes in civil suits. It is no answer, beyond political window dressing, to

retain outside counsel. Whoever her agents may be, whether her permanent staff

or outside special appointments, they must function under the Attorney General's

direction. And the Attorney General must be allowed to fulfill the responsibilities

of that office unless and until circumstances arise which would compel the Court

to interrupt the fulfillment of those responsibilities. No such case has been made

out. II


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The court referred to the appellant's factum, having found itself "in essential agreement" with a

longer passage containing this statement:

There is a presumption that the Attorney General will carry out her duties in good

faith which is supported by the common law, legislation, policy and constitutional

convention. 12

An appeal went of right to the Supreme Court of Canada. Lamer C.J. delivered an oral judgment

dismissing the appeal, stating simply that "the appellant has not established any conflict of

interest or appearance thereof, which would affect his right to be prosecuted fairly".

In R. v. Evic 13, the Nunavut Court of Justice was called on to consider the appropriate role of

prosecutors where the same person is an accused in one proceeding and a witness in another and

the same prosecutions office conducts both proceedings. In denying the application to remove

the prosecutors, Johnson 1. noted the similarity to the fact situation in R. v. D.:

The argument of Counsel for the Applicant is similar except that the Attorney

General is calling the witness and prosecuting him in separate criminal

proceedings, rather than in separate civil and criminal proceedings that occurred

in R. v. D. (W.R.). In my opinion, the principles are the same and I adopt the

same words of the Court ofAppeal.

There are, no doubt, mixed opinions about the fairness of this approach. The trial

judge in R. v. D. (W.R.) certainly felt that there would be a perception in the

public that the Crown might not be fully prosecuting the case because of the

impact on the civil action. If there was an acquittal in the criminal trial, the civil

action might have been seriously compromised even though there is a different

standard of proof. While this concern was understandable, the Court of Appeal

presumed the good faith of the Office of the Attorney General and placed the onus

on the party alleging the conflict to provide some basis for suggesting an oblique


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motive. There is even less reason to suspect the motives of the Crown in this case,

where there was no financial consequence to the Crown. The only suggestion of

potential impropriety was the possible undue influence that might be exerted on

the complainant as a witness, using the prosecution as a lever to obtain the desired

testimony, particularly where there was a reluctant witness and a s.9(2)

application engaged. While this oblique motive was possible, the good faith of the

Attorney-General is presumed. 14

However, he went on to state:

The situation that is problematic for the Crown is where the same prosecutor is

handling both files. This leaves open the possibility that the relationship with the

accused as a witness might be exploited by the prosecutor in prosecuting him. 15

The possibility that a prosecutor would be called on to cross-examine a witness that the

prosecutor had at one time represented was considered recently in Standingwater v. R. 16 The

prosecutor discovered, during her preparation for a dangerous offender application, that she had

represented the accused some 19 years earlier on a criminal matter while she was with the Legal

Aid Commission. However, she could not remember any of the discussions with the accused in

relation to the earlier matter or any information that might have been passed to her by the

accused. Notwithstanding the passage of time and the prosecutor's lack of a specific memory of

the events, the court allowed the application to remove her, based in part, it would appear, on the

risk that she would unknowingly use confidential information obtained from the accused in

relation to the earlier matter and the specific possibility that she would come to cross-examine

the accused during the course of the proceedings. It may also be that the court was moved to this

ruling by the nature of an application for dangerous offender designation, where the accused's

entire criminal history has greater relevance than in an ordinary criminal trial.


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The court declined to grant an order enjoining other prosecutors in the same office from handling

the case going forward, provided the prosecutor would have no further input. This may be an

illustration of the apparently increasing tendency of the courts to find workable solutions in

conflicts cases.

LIFE AFTER GOVERNMENT PRACTICE

Government lawyers may have one advantage on leaving government practice, at least as it

relates to the application of the duty of confidentiality and transfer rules. Problems related to the

duty of confidentiality and lawyer transfers arise in the main, although not exclusively, where

former clients want to impose rigid rules on departing lawyers and their new firms. Sometimes

these actions are purely tactical and not based on real concerns about the use of confidential

information.

Governments have a vested interest in ensuring that lawyers who leave their employ can move

on to other gainful employment. Governments want to be seen as good employers, and it is not

in the government's interest to make life difficult for a departing lawyer. As a result,

governments will normally provide whatever consents are necessary to allow departing lawyers

to carryon life in their new work setting in the most favourable manner possible, without

imposing unnecessary limitations that are not based on the protection of meaningful interests.

However, these choices are not always left entirely to the government employer of the departing

lawyer. For example, if the transferring lawyer has been involved in a complex file involving

more than one client where clients with similar interests have shared confidential information,

one of those other clients with whom confidential information has been shared may be able to

impose restrictions on the lawyer's transfer based on the duty of confidentiality.

The decision of the Ontario Superior Court of Justice in Tiboni v. Merck Frosst Canada Ltd. 17

illustrates another limitation for lawyers leaving the government related to their former status as

public officers or public employees. This is an ongoing class action where the plaintiffs are


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suing Merck in negligence related to its manufacture and sale ofVioxx. The plaintiffs are

represented by the firm of Sutts Strosberg, where Allan Rock, formerly a federal Minister of

Health, is a partner. Mr. Rock was actively engaged in the lawsuit.

Merck's counsel brought a motion to disqualify Mr. Rock, his firm and certain other associated

law firms involved in the suit, on the basis that Mr. Rock, while Minister of Health, would have

received, or must be deemed to have had knowledge of, confidential information regarding

Vioxx, some of which was provided by Merck, and that he must have, or be deemed to have,

participated in deliberations regarding the approval and regulation of Vioxx and to have been

responsible for the decisions of his department with respect to it.

Mr. Rock swore an affidavit to the effect that he had obtained no knowledge about Merck's

application for Vioxx while minister and that the scale of the system made it practically

impossible for ministers to be involved in such matters. He acknowledged that he had been

politically accountable for the work in his department, but that he was entirely isolated from the

actual drug approval processes.

The court was not prepared to impute to Mr. Rock the information acquired and held by

members of his department. Nonetheless, he was disqualified on the basis of rule 6.05(5) of the

Rules ofProfessional Conduct of the Law Society of Upper Canada:

6.05 (5). A lawyer who has left public office shall not act for a client in

connection with any matter for which the lawyer had substantial responsibility

before leaving public office.

The court set out the underlying principles supporting this rule as follows:

Public perception is important if confidence in the integrity ofthe administration

ofjustice and of public institutions is to be maintained. A reasonable and


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informed person might well have an apprehension that a former Minister of the

Crown, who was retained in a matter in which the conduct of his department

during his period of office may be in question, could have divided loyalties to an

extent that they would interfere with his ability to make decisions objectively and

exclusively in the interests of his present clients. I would not accept any purported

waiver of such a conflict on behalf of the putative class in this case.

Even apart from any perception of divided loyalties, I believe that rule 6.05 (5)

reflects a policy that public confidence in the integrity of governmental

institutions and the courts would suffer if the former holders of public officers

(sic) were permitted to represent parties in private litigation over matters for

which the officers hadpreviously had a substantial public responsibility. This

would be a public interest conflict in the sense used in the cases I have mentioned

above and, as such, it could not be waived. 18

With Mr. Rock disqualified, the court moved to consider whether his law firm and the associated

counsel should similarly be disqualified:

Given my rejection of the defendants' reliance on confidential information that is

said to have been possessed by Mr Rock, the other factors that I believe should be

considered to disqualify him from participation in the proceedings do not extend

to Sutts Strosberg and the Associated counsel. They are essentially factors that

arise from, and are exclusively referable to, his status as a Minister of the Crown

in charge of a governmental department.

I do not accept that his participation to date has been anything but de minimis and

that it is now too late to set up an insulating screen. The statements and the

authorities to the effect that such a screen will be effective only if it is set up at the

time a solicitor joins his present firm -like the comments about "conclusary"

affidavits in MacDonald Estate - were made in the context of an inference, or


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presumption, that solicitors in a firm will share confidential information. By itself,

Mr Rock's status as a former holder of a public office does not taint any other

members of the firm. It might possibly do so ifhe had been actively engaged on

behalf of the firm in the preparation ofthe plaintiffs' case. There is, however, no

presumption to this effect and, in this context, I see no reason for rejecting his

evidence of the minimal extent of his involvement, or for believing that it might

not withstand the scrutiny of reasonable and informed members of the public. 19

The court in Tiboni referred extensively to the decision of Wright 1., in his capacity as the sole

commissioner in the Stonechild Inquiry, related to an application to remove counsel for the

Federation of Saskatchewan Indian Nations.2o The FSIN, as a party before the commission,

retained the Robertson Stromberg law firm. The firm intended to use the services of Chris

Axworthy, a former Minister of Justice, on the file. One of the other parties before the

commission applied to the commissioner to remove both Mr. Axworthy and the firm.

Rule XIX Commentary 3 of the Law Society of Saskatchewan's Code ofProfessional Conduct

contains a provision similar to that contained in the Ontario code and on which Tiboni was

based:

After leaving public employment, the lawyer should not accept employment in

connection with any matter in which the lawyer had substantial responsibility or

confidential information prior to leaving, because to do so would give the

appearance of impropriety even if none existed.

The commissioner found this to be directly on point and, since Mr. Axworthy, as Minister of

Justice, had substantial responsibility with respect to the matter before the inquiry, he was

disqualified. This was so whether or not the Government of Saskatchewan was prepared to

waive the duty of confidentiality owed to it by Mr. Axworthy, since the disqualification was

necessary as a matter of public confidence.


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However, Tiboni and Stonechild divurge with respect to the effect of the lawyer's

disqualification on the lawyer's firm. The commissioner in Stonechild was not prepared to see

Robertson Stromberg continue. It would appear this was based on the particular facts in play,

perhaps mainly because the firm had not put any screening measures in place at the outset of

their involvement on the file.

CLOSING THOUGHTS

While government lawyers and government law offices are different in some ways - special

responsibilities, unique realities associated with scale - they face most of the same issues faced

by lawyers and law offices in other settings. In most instances, the conflicts rules established by

the courts and by the rules of the regulating bodies apply to government lawyers in the same way

they apply to lawyers generally. Government lawyers, like all other lawyers, must act

accordingly.


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REFERENCES

1. MacDonald Estate v. Martin, [1990] 3 S.C.R. 1235 atp. 1265.

2. R. v. Neil, [2002] 3 8.C.R. 631 at para. 31.

3. Ibid. at para. 29.

4. Letter from the Chair in the task force's October 2007 consultation paper.

5. Neil, supra at para. 28.

6.2006 SKCA 87.

7. This is a minor, although intentional, mischaracterization. In Saskatchewan, at the time of

Kimmie, the Minister of Justice was, by virtue of The Department ojJustice Act, ex officio the

Attorney General. As a result, one minister served as both. The Act gave each of the offices

distinct powers. In addition, the Attorney General was given authority related to the conduct of

prosecutions under the Criminal Code. The Minister of Justice, as opposed to the Attorney

General, commenced an appeal pursuant to s. 830 of the Criminal Code against an order

appointing counsel for the accused. The Minister of Justice was represented by a lawyer from

the Public Law Division, rather than the prosecutor who had carriage of the file, following a

practice in Saskatchewan that prosecutors normally do not represent the government on related

civil matters associated with a prosecution. The result likely does not hinge on Saskatchewan's

separation of the offices in its legislation.

8. 8.S. 1983, c. L-9.1.

9. Responsibilities assigned to Saskatchewan's Minister of Justice and Attorney General are

contained in The Department ojJustice Act, 8.S. 1983, c. D-18.2.


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10. [1994] 5 W.W.R. 305.

11. Ibid. at paras. 11 to 13.


13. 2005 NUCJ 25.

14. Ibid. at paras. 19 and 20.


16. 2007 SKQB 484, December 21,2007. See also R. v. Lindskog, 1997 CanLII 11318 .

(SKQB).

17. 2008 CanLII 6872.



20. Report of the Commission of Inquiry Into Matters Relating to the Death ofNeil Stonechild,

October 2004, pp. 104 to 130.


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