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Judge Rakoff Says AI Chatbot Documents Are Not Privileged or Work Product

The decision applies long-standing third-party disclosure principles to consumer AI tools.

Overview

  • Ruling from the bench on Feb. 10 in United States v. Heppner held that about 31 documents a defendant generated with a consumer chatbot are not protected by attorney-client privilege or the work product doctrine.
  • The court found the AI provider’s terms permitted training and disclosure, defeating the confidentiality required for privilege, and later sharing the materials with counsel did not retroactively create protection.
  • Work product did not apply because the defendant created the documents on his own initiative rather than at the direction of his attorneys.
  • The ruling addresses a narrow fact pattern involving a consumer AI platform and leaves open how enterprise contracts guaranteeing confidentiality or attorney-directed use might be treated.
  • No written opinion has been issued yet, and legal commentators urge organizations to review AI policies, distinguish consumer from enterprise tools, and route AI-assisted legal work through counsel as Heppner heads toward an April 6 trial.