a disclosure order and a delayed potential appeal is unlikely to interfere with attorney–client communications. The Court noted that parties subject to an adverse disclosure order regarding attorney–client privilege have other options besides a collateral order appeal, such as the certification and acceptance of an interlocutory appeal under 28 U.S.C. Section 1292(b), petitioning for a writ of mandamus, or by defying the order and incurring court-imposed sanctions such as a contempt of court citation which is immediately appealable. The Court predicted that including privilege-related disclosure orders within the category of collateral orders would not justify the institutional cost, because it would delay the resolution of cases in the district courts and would unnecessarily burden the Courts of Appeals. The collateral order doctrine does not extend to disclosure orders adverse to the attorney–client privilege. References External links United States Supreme Court cases 2009 in United States case law United States Supreme Court cases of the Roberts Court United States attorney–client privilege case law