Part I examines the courts' current certainty-based perspective, and rejects this approach because it sacrifices important interests in civil law enforcement and judicial consistency for speculative and coincidental reductions in grand jury abuse. Part II defends the proposed standard by arguing that it comports with the language and intent of the rule while more effectively advancing the policy interests in civil law enforcement and grand jury secrecy.
Michigan Law Review,
Federal Agency Access To Grand Jury Transcripts Under Rule 6 (e),
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol80/iss8/4