In re Grand Jury Investigation No. 83-2-35 (Durant)

A grand jury investigating stolen checks sought the identity of a client who allegedly used one of the stolen checks to pay attorney Durant (defendant) for legal services; Durant refused to disclose the client's identity, arguing disclosure would implicate the client in the underlying theft, supply the last evidentiary link needed for indictment, and reveal guilt since the theft itself was the subject of Durant's legal services, but he never sought an ex parte in camera hearing to substantiate these claims. The district court ordered disclosure, held Durant in contempt when he still refused, and Durant appealed.