In Commodity Futures Trading Commission v. Weintraub, 471 U.S. 343 (1985), the Supreme Court held that "the trustee of a corporation in bankruptcy has the power to waive the corporation's attorney-client privilege. . . ." Id. at 358. The Court asserted first that, for solvent corporations, the power to waive the privilege rests with the officers and directors. Id. at 348. It then reasoned that control of a corporation's attorney-client privilege in bankruptcy belongs to the party having the most analogous duties to the solvent corporation's officers and directors. Id. at 351. The Court concluded that the duties of the bankruptcy trustee are most similar to the duties of the officers and directors of a solvent corporation; therefore, the bankruptcy trustee controls the privilege. Id. at 353. In holding that the bankruptcy trustee may waive the attorney-client privilege on behalf of a corporation, the Court cautioned that a bankrupt individual presents a different situation: Our holding today has no bearing on the problem of individual bankruptcy, which we have no reason to address in this case. As we have stated, a corporation, as an inanimate entity, must act through its agents. When the corporation is solvent, the agent that controls the corporate attorney-client privilege is the corporation's management. Under our holding today, this power passes to the trustee because the trustee's functions are more closely analogous to those of management outside of bankruptcy than are the functions of the debtor's directors. An individual, in contrast, can act for himself; there is no "management" that controls a solvent individual's attorney-client privilege. Id. at 356.