I doubt it. According to the 1960s courts, they did because this “ancient concept” was essentially common sense. If you tell someone something, you shouldn’t expect a constitutional right to it remaining a secret. If I told someone I robbed a bank and my confidant calls the police, why shouldn’t they use this information? Should the courts respect mafia NDAs?

The banking aspects didn’t show up until the mid 70s. Personally, I think technology changed society in ways the constitution isn’t prepared for. In 1790 a banker was a dude you worked with in a local institution. In 1975 half of California was a Bank of America customer.

The constitution didn’t anticipate this and you’d need an amendment to create some sort of agent or attorney like privilege. It’s a fairly nuanced issue — from the humans point of view, an email is like a letter, and Google Drive is like a file cabinet. But the courts are forced to think about the where the logical artifact (ie the folder) is located. A USB drive in a drawer is protected, but the file in Google is not.