GARNER DOCTRINE

Garner doctrine. The rule that allows shareholder plaintiffs in a corporate derivative action to

discover confi-dential communications between a corporate officer and the corporation’s attorney.

  • The Garner doctrine does not apply to attorney work product, and the movant must show good

cause.Garner v. Wolfinbarger, 430 F.2d 1093 (5th Cir. 1970). See DERIVATIVE ACTION(1).

[Cases: Federal Civil Procedure 1600; Witnesses 197. C.J.S. Witnesses §§ 316–340.] [Blacks Law 8th]