https://www.stroock.com/news-and-insights/u-s-supreme-court-dismisses-cert-in-case-concerning-scope-of-attorney-client-privilege-for-dual-purpose-communications

https://www.stroock.com/news-and-insights/u-s-supreme-court-dismisses-cert-in-case-concerning-scope-of-attorney-client-privilege-for-dual-purpose-communications https://www.stroock.com/news-and-insights/u-s-supreme-court-... provides some more context - and speculates as to why the court declined to take the opportunity to definitively establish a standard here. It seems to still be an open question what the standard is!