After stabbing and killing John Warren in a fight, Henry Gray was arrested. Gray retained David Olwell (defendant) to represent him. While in jail, Gray conferred with Olwell about the case. At some point, Olwell came into possession of a knife that might have been used in the crime. A coroner’s inquest was called to investigate the circumstances of the crime. Olwell was served with a subpoena demanding production of all knives in his possession relating to Gray or Warren. Olwell refused to comply, claiming attorney-client privilege. The King County Superior Court (plaintiff) found Olwell in contempt based on his refusal to produce the knife. After Olwell again refused to turn over the knife, he was directed to serve two days in jail. Olwell appealed.