Section 14.23 Waiver Must Be Voluntary

• Library: Evidence 2017

c. (§14.23) Waiver Must Be Voluntary

For a party to waive a confidential privilege such as that of attorney-client, the waiver must be voluntary; cross-examination does not waive privilege. State ex rel. DeGraffenreid v. Keet, 619 S.W.2d 873, 878 (Mo. App. S.D. 1981); see also State ex rel. Hayter v. Griffin, 785 S.W.2d 590, 594 (Mo. App. W.D. 1990) (recognizing the...