Sixth District Court of Appeals for the State of California

At the end of 2025, amendments were made to the Federal Rules of Civil Procedure that fundamentally change when and how litigators must address privilege issues in federal court. These amendments followed an important decision in the Sixth Circuit in In re FirstEnergy Corp., 154 F.4th 431 (6th Cir. 2025), which provided practitioners fresh guidance for protecting privileged materials early in the litigation. Understanding these developments and beginning to plan around privilege at the outset of a case is essential for anyone litigating in federal court today.