In Sacramento Brewing co. v. Desmond, Miller & Desmond (1999) 75 Cal.App.4th 1082, the Court traced the history of the litigation privilege requirement that a communication made in a judicial proceeding have a "logical relation" to the action. The Court noted that there was a line of cases, never expressly overruled, that do not require a publication made in a judicial proceeding to have a logical relation to the action. ( Id. at p. 1086.) The Court concluded that the logical relation requirement must not be rigidly applied to in-court communications, and that the privilege should be denied "only where it is so palpably irrelevant to the subject matter of the action that no reasonable person can doubt its irrelevancy." ( Id. at p. 1089.) The Court noted that the test still includes the requirement that the communication be "'in furtherance of the objects of the litigation.'" (Ibid.)