North Dakota Supreme Court

Anne Carlsen Center v. LeFevre

July 31, 20252025 ND 142

Summary

The North Dakota Supreme Court granted a supervisory writ and vacated the district court’s discovery order because it did not explain, with sufficient specificity, why each asserted privilege or protection failed or how agreed redactions should be handled. The Court directed the district court to reconsider the motion on a document-by-document and privilege-by-privilege basis, recognizing that the party asserting protection bears the burden of supporting the claim with intelligible materials. The Court also clarified the limits of statutory confidentiality, attorney-client privilege, and work-product protection.