As this chapter notes, federal courts are split about whether government officials could invoke the attorney-client privilege for communications with government lawyers. In the 2014 case of In re 33rd Statewide Investigating Grand Jury, 86 A.3d 204, the Pennsylvania Supreme Court held that a state agency under investigation by the state attorney general could not invoke the privilege to prevent the agency’s general counsel from giving information to the attorney general. What was the court’s reason for its decision? Who is the “client” in these cases?