"In response to Starr's argument that posthumous exceptions had been granted before, and that interest in whether a crime had been committed was sufficient reason to do so, the opinion noted that exceptions had been granted based on an implied waiver in order to fulfill the client’s testamentary intent (and necessarily implied the posthumous survival of attorney-client privilege), such as in estate disputes among heirs, and that there was no reason to suppose that "grand jury testimony about confidential communications furthers the client’s intent.