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Western Sugar Cooperative v. Archer-Daniels-Midland Co.

United States District Court for the Central District of California
98 F. Supp.3d 1074 (2015)


Facts

Sugar producers, including Western Sugar Cooperative (plaintiff), sued corn-syrup producers, including Tate & Lyle Ingredients Americas, Inc. (Tate & Lyle) (defendants), for false advertising in 2011. The law firm of Squire Sanders represented the sugar plaintiffs. In 2014, Squire Sanders merged with the law firm of Patton Boggs to form Squire Patton Boggs (SPB). Patton Boggs had represented Tate & Lyle since 1998. After learning of the conflict, SPB asked Tate & Lyle for a conflict waiver. Tate & Lyle refused to waive the conflict and requested that SPB withdraw from representing the sugar plaintiffs. SPB at first proposed to carry on representing both the sugar plaintiffs and Tate & Lyle with two distinct teams of lawyers and sent Tate & Lyle a copy of a general advanced consent waiver that Tate & Lyle had signed in 1998, when it became Patton Boggs’ client. SPB then terminated its representation of Tate & Lyle. Tate & Lyle filed a motion to disqualify SPB from representing the sugar plaintiffs, alleging that SPB was simultaneously representing adverse clients.

Rule of Law

Issue

Holding and Reasoning (Marshall, J.)

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