People of the State of New York v. PricewaterhouseCoopers LLP

The New York Appellate Division affirmed a trial court order requiring Exxon Mobil Corporation’s (Exxon’s) accounting firm to comply with a subpoena from the New York State Attorney General in its investigation into Exxon’s climate change-related disclosures. The Appellate Division ruled that the court below had properly found that New York law on privilege applied and did not recognize an accountant-client privilege. The appellate court rejected Exxon’s contention that courts should apply an “interest-balancing analysis” to decide whether New York or Texas choice of law should govern the evidentiary privilege.

Exxon Mobil Corporation (Exxon) filed a brief arguing that the New York Appellate Division should reverse a trial court ruling that an evidentiary accountant-client privilege created by Texas law did not bar the trial court from ordering Exxon's accounting firm to produce certain documents.