In re Investigating Grand Jury (Stretton)

"Mr. Y" (defendant), sentenced to death after being convicted based partly on evidence developed with attorney Samuel Stretton's help before Stretton withdrew as counsel during the appeal, later called Stretton from prison to vent frustration about the case's outcome, without being told the call wasn't privileged and while it was unclear whether he had yet reached his newly appointed appellate counsel. After DNA evidence eventually vacated Mr. Y's sentence and he was released, the state re-investigated based on the theory that his angry prison call to Stretton contained incriminating admissions, subpoenaing Stretton to testify before a grand jury; Stretton asserted privilege and refused, resulting in a contempt finding and daily fine.