In re January 1976 Grand Jury (Genson)
United States Court of Appeals for the Seventh Circuit
534 F.2d 719 (1976)
Attorney Genson (defendant) received $200 in cash from his former employee Paul Bijeol shortly after Bijeol was arrested on suspicion of bank robbery, and told an FBI agent he had received something from Bijeol but refused to identify it, invoking attorney-client privilege. When Genson was subpoenaed to produce any money received from Bijeol or his accomplice, he moved to quash, was denied, and was held in contempt for continued refusal to comply.
Does the Fifth Amendment privilege against self-incrimination or the attorney-client privilege afford grounds for an attorney to refuse compliance with a grand jury subpoena demanding production of money received from a client when production would provide evidence relevant to a criminal prosecution?