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In re Grand Jury Subpoena

United States Court of Appeals for the Fourth Circuit
204 F.3d 516 (2000)


Facts

A grand jury was investigating whether Erskine “Pee Wee” Hartwell and other people were operating an open-air drug market at property located at 37 Forrester Street in Washington, D.C. (the property). The record owner of the property was Daniel C. Quispehuman, and the government believed this was a straw owner. A nonprofit community organization, Bellview Improvement Council Inc. (BIC), retained an attorney, Mark S. Davies, to stop the drug activity at the property. Davies sent letters to Quispehuman, demanding he stop the drug activity and threatening to sue. An attorney, Mark Rochon, responded, saying that he would be clarifying the owner of the property, that his client hoped to retitle the property, and requesting two weeks to do so to avoid needless litigation. A few months later, the government served a grand-jury subpoena on Rochon, seeking several documents and testimony regarding the identity of Rochon’s client. Rochon refused to identify his client, claiming his identity was subject to the attorney-client privilege.

Rule of Law

Issue

Holding and Reasoning (Wilson, C.J.)

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