Hall v. Google LLC
- Jon Tigar
- 4:23-cv-06574
- U.S. District Court · Northern District of California
- 2
Counsel of record per CourtListener. Firm names are approximate and have been consolidated across spelling variants.
In Hall v. Google LLC, Magistrate Judge Alex G. Tse allowed Jalon R. Hall to keep spiritual-advice text messages redacted during discovery.
Jalon R. Hall, who did not have to produce unredacted versions of the specified text messages.
What happened
Hall v. Google LLC concerns text messages between Jalon R. Hall and her father, an ordained minister. Hall claimed that some messages were protected by the clergy-penitent privilege.
After reviewing the newly found messages privately, the court said the redacted portions were plausibly protected because they contained spiritual advice or counseling. The court also said the messages did not relate to any party’s claim or defense, so Hall did not have to produce unredacted versions.
Magistrate Judge Alex G. Tse issued the discovery order on July 25, 2025.
The detailed version
- Hall v. Google LLC · No. 4:23-cv-06574
- Jon Tigar
- July 25, 2025
Background
Jalon R. Hall invoked the clergy-penitent privilege for text messages with her father, who is an ordained minister. In an earlier review, the court held that most of the messages then at issue were not protected and ordered Hall to produce them.
Hall later found additional messages with her father. She redacted portions of those messages and submitted them for the court’s private review, again invoking the clergy-penitent privilege. The messages at issue were identified as HALLO001068–73.
Court’s Analysis
The court explained that federal common law protects a confession made by a person to a minister acting in that capacity when the person seeks spiritual help. The court found that Hall had redacted only messages in which her father offered spiritual advice or counseling. Because of their content, the court said the redacted messages were plausibly protected by the privilege.
The court added that, even if the privilege did not apply, the messages were not relevant to any party’s claim or defense under Federal Rule of Civil Procedure 26(b)(1).
Ruling
The court ordered that Hall did not have to produce unredacted versions of the redacted messages. Magistrate Judge Alex G. Tse issued the discovery order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.