Defendant, a nonresident citizen of the United States, was subpoenaed by a federal district court to appear before a grand jury investigating alleged fraud in the procurement of government contracts. Defendant having failed to appear, the district court issued an order directing him to show cause why he should not be held in contempt. On appeal from a judgment holding defendant in contempt, held, reversed, one judge dissenting in part. The power of a federal district court to subpoena a nonresident citizen is limited to the actual trial of a criminal action. United States v. Thompson, 319 F.2d 665 (2d Cir. 1963).
Andre A. Schwartz,
Federal Criminal Procedure-Subpoena of Nonresident Citizen as Witness Before Grand Jury,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol62/iss6/12