In the Matter of Herschel Kozlov, Esquire, Charged With Contempt of Court

Summary

The Supreme Court of New Jersey reversed Herschel Kozlov's criminal contempt conviction, holding that the attorney‑client privilege in this case extends to the identity of the client and that the trial court erred by imposing contempt without first exhausting less intrusive means of inquiry. The Court remanded for further proceedings to determine the juror's bias and any appropriate new trial. Justice Handler, concurring, agreed with the result but expressed reservations about extending the privilege to client identity.