California, United States of America
The following excerpt is from People v. Clark, 268 Cal.Rptr. 399, 50 Cal.3d 583, 789 P.2d 127 (Cal. 1990):
The authorities relied upon by the People do not support the argument that the attorney-client privilege does not extend to statements of intent to commit future crimes. United States v. Friedman (9th Cir.1971) 445 F.2d 1076 said that communications lose their privileged character "when they concern contemplated unlawful acts by the client. Calif.Evid.Code, 956 ..." (id. at p. 1085), but in a more complete statement correctly held: "The attorney need not himself be aware of the illegality involved; it is enough that the communication furthered, or was intended by the client to further, that illegality." (Id. at p. 1086.)
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