A recent opinion from the Third Circuit highlights why it is important to consider past legal work when reviewing preliminary conflicts checks. In De La Cruz v. Virgin Islands Water & Power Authority, No. 13-4623, 2014 WL 7398889 (3d Cir. Dec. 30, 2014), the court affirmed the district court's decision to disqualify the plaintiff's law firm because one of its associates previously worked for the defendant on a substantially related matter. Plaintiff was electrocuted when his painting equipment hit a power line. The associate in question previously represented the defendant power company in a personal injury case involving contact with electrical infrastructure. The Third Circuit agreed with the lower court's findings that the matters were substantially related and disqualification was warranted, noting "[t]he cases may not have involved the same plaintiffs, the same locations, or the same source of electrocution but they were nevertheless similar enough to create a genuine risk that [the associate] obtained confidential information from [the defendant] during his work on the [previous] matter."