Bradford Lund v. Hon. Myers, 305 P.3d 374

Lund relatives seek guardian/conservator for Bradford Lund; Lunds oppose petition.
Miller's counsel served JS&S with subpoena for non-privileged Bradford info; Murphy disclosed entire file believing he represented Bradford.
Bradford's counsel learned of disclosure and notified Murphy; Murphy distributed file to others in case per Miller's disclosure statement.
Lunds move to disqualify Murphy and B&C for reading/retaining privileged materials; JS&S moves to compel compliance with inadvertent-disclosure rules.
Trial court permits Murphy to retain file but bars copying or conveying; orders JS&S to prepare a privilege log; later, JS&S to intervene.
Court of Appeals stayed, holding that in camera review is not unbounded and must follow Rule 26.1(f)(2) thresholds; this Court grants review to clarify privilege-review procedures.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must in camera review be shown necessary before reviewing documents	Lunds: review should not occur without threshold showing.	Miller/JS&S: broad right to in camera review under Rule 26.1(f)(2).	Yes; threshold necessary before in camera review.
Is reviewing all documents appropriate before privilege/waiver argument	Should await privilege log responses and arguments before reviewing.	Court may review to determine privilege status.	court should await privilege-log responses and arguments before reviewing documents

United States v. Zolin, 491 U.S. 554 (1989) (threshold showing required for in camera review regarding crime-fraud exception)
Kline v. Kline, 212 P.3d 902 (App. 2009) (prima facie evidence required for exceptions)
State Farm Mut. Auto. Ins. Co. v. Lee, 13 P.3d 1169 (Ariz. 2000) (discovery rulings on privilege reviewed for abuse of discretion)