Response or Comment
Hale, the plaintiff in the case of Hale v. Henkel, supra, was served with a subpoena duces tecum, commanding him to produce before the grand jury all contracts, memoranda, correspondence, reports, letters, etc., having to do with the business of the MacAndrews & Forbes Company. He pleaded immunity from the operation of the subpoena under the 4th amendment, which prohibits unreasonable searches and seizures. The Court held that an order for the production of books and papers may constitute an unreasonable search and seizure within the 4th amendment.
Sunderland, Edson R. "Compelling the Production of Corporation Books and Papers." Mich. L. Rev. 4 (1906): 635.