U.S. v. Doe Corporation

Dist. Ct. erred in granting defendant’s motion to quash grand jury subpoena seeking security footage of federal and state officials performing search of defendant’s premises, under circumstances where defendant had accused said agents of pointing guns at defendant’s employees during said search, Record showed that federal government was investigating defendant for suspected criminal violations of Clean Water Act, and that grand jury was in process of investigating said violation. While Dist. Ct. granted defendant’s motion to quash grand jury’s subpoena based on belief that any misconduct in carrying out search warrant was not relevant to grand jury’s investigation into defendant’s alleged Clean Water Act violations, Ct. of Appeals held that instant allegations of government misconduct was relevant to said investigation, where: (1) grand jury could properly find that any misconduct demonstrated improper animosity towards defendant as target of instant investigation; and (2) said video could resolve question as to whether there was admissible evidence to support any Clean Water Act violation charge. Also, Ct. of Appeals observed that video was relevant on issue of whether evidence was collected in such manner so as to call into question its reliability,