Criminal Procedure keyed to Kamisar
United States v. R. Enterprises, Inc
Subpoenas were issued to three adult materials distributors in connection with a grand jury investigation into allegations of the interstate transport of obscene materials. The companies moved to quash the subpoenas on the grounds that they were irrelevant and that it was likely that they would infringe on the First Amendment constitutional rights of the companies. The District Court denied those motions. The Court of Appeals remanded the motions to quash certain of the business records, holding that the Nixon test of relevancy, admissibility and specificity established by the Supreme Court of the United States (“Supreme Court”) in the trial context was equally applicable to the grand jury context.
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