United States v. R. Enterprises, Inc.
United States Supreme Court
498 U.S. 292 (1991)
A grand jury investigating interstate transportation of obscene materials subpoenaed business records and videotapes from R. Enterprises (defendant) and two other companies. The companies moved to quash; the district court denied the motion, but the court of appeals reversed and quashed the subpoenas issued to two of the three companies, applying the relevancy, admissibility, and specificity requirements the Supreme Court had set for trial subpoenas in United States v. Nixon.
Whether it is error for a court to quash a grand jury subpoena duces tecum in the absence of a determination that there is no possibility the materials sought by the subpoena will produce evidence relevant to the subject of the grand jury investigation.