United States v. Sells Engineering, Inc.
United States Supreme Court
463 U.S. 418 (1983)
After Sells Engineering and two officers (defendants) were indicted for tax fraud, the Department of Justice's Civil Division sought access to the grand jury materials to pursue a related civil suit, and the district court granted that request without requiring any special showing. The court of appeals held the Department needed to demonstrate a particularized need under the federal rules governing grand jury secrecy, and the Department sought Supreme Court review.
Whether a government attorney seeking grand jury materials to pursue a related civil case is automatically entitled to disclosure, or must instead show a particularized need justifying disclosure despite the secrecy ordinarily attached to grand jury proceedings.