The Buried Bodies Case, also known as the Lake Pleasant Bodies Case, is a mid-1970s upstate New York court case where defense attorneys Frank H. Armani and Francis Belge kept secret the location of the bodies of two women murdered by their client, Robert Garrow, Sr.[1]
Ahead of trial for an unrelated murder, Garrow confessed to his lawyers that he had murdered two missing women and hidden their bodies.[1][2] Armani and Belge found the women's bodies but chose to keep the information confidential.[2] Authorities continued to search for the missing women for months as their families grieved.[1][2] When the public discovered Armani and Belge had kept this information secret, they faced criminal charges and disbarment proceedings.[2][3] The attorneys claimed they were bound by the duty of confidentiality not to disclose information that could incriminate their client.[3] Armani and Belge were later absolved of any wrongdoing.[4]
The case has become a touchstone in legal ethics courses.[1][4] It highlights lawyers' ethical obligation to keep their clients' information confidential.[5][6] It also showcases the ethical questions that can arise for lawyers related to confidentiality, attorney-client privilege, and clients' self-incrimination.[5] The case has helped shape the development of ethical rules on confidentiality.[4]
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