[1][2] When the public discovered Armani and Belge had kept this information secret, they faced criminal charges and disbarment proceedings.
[5][6] It also showcases the ethical questions that can arise for lawyers related to confidentiality, attorney–client privilege, and clients' self-incrimination.
[1][5] With no experience in murder trials, Armani recruited his friend Francis Belge, an experienced criminal defense attorney, to help represent Garrow.
[1] Garrow also claimed he murdered and hid the bodies of two missing women, Susan Petz and Alicia Hauck.
[4] They used Garrow's diagram to uncover Petz's body in an airshaft of a coal mine in Mineville, NY.
[1][7] Belge later uncovered Hauck's body in a Syracuse, NY cemetery based on Garrow's description.
[4] They told the prosecutor that they might be able to provide information to help authorities find the missing women if Garrow were sentenced to life in a mental hospital rather than prison.
[1] During direct examination of Garrow, Belge asked, “Is that the one I found?” implying that he was aware of the dead women prior to trial.
[3] Belge was indicted for allegedly violating two state public health laws by failing to disclose his discovery of the dead bodies.
"[15] One of the victims' parents filed ethics complaints against Armani and Belge with New York State Bar Association disciplinary officials.
[9][16] The committee explained that the attorneys would have violated their ethical obligations to keep their client's confidential information secret if they had disclosed the details to authorities.
[9] The ethics opinion emphasized that the attorney–client privilege is necessary to ensure clients disclose all possible pertinent information to their lawyers.
[9][16] It further explained that disclosure of all possibly pertinent information allows attorneys to craft the strongest defense and protect their clients' rights to the fullest extent.
[11] The central question Armani and Belge faced was whether to disclose the location of the missing women's bodies.
[3][10] The case showcases the tension between protecting a client's interest and the potential emotional harm that victims, their family, or a community might experience.
[4] For example, scholars have asked whether Armani and Belge would have been required to assist the women or disclose their locations had they been found alive.
[5][17] One exception adopted by some states is that a lawyer may reveal client information if they believe the disclosure is necessary to prevent reasonably certain death or substantial bodily harm.
[4] Several legal scholars believe Armani and Belge acted ethically in refraining from sharing their client's confession.
[4] The exception states that a lawyer may reveal information relating to their client if they reasonably believe it is necessary "to prevent reasonably certain death or substantial bodily harm.
"[6] This exception, added by amendment in 2002, was hotly contested; lawyers worried the language might erode the duty of confidentiality.
[4] The Buried Bodies Case provided professors with an example in the mid-1970s of how ethical issues could be taught from a human perspective with real world problems.
[24] Similarly, some have considered a new exception to confidentiality rules to allow disclosure when victims suffer severe emotional harm.
[16] Moreover, others criticize the case for exempting lawyers from laws, like the public health code requiring the disclosure of dead bodies, that apply to everyone else.
[14] The case has been the subject of numerous books, including Privileged Information by Tom Alibrandi with Frank Armani (1984)[2] and Terror in the Adirondacks: The True Story of Serial Killer Robert F. Garrow by Lawrence Gooley (2009).