Wright v. Jeep Corp.
United States District Court for the Eastern District of Michigan
547 F. Supp. 871 (1982)
- Written by Mike Begovic, JD
Facts
Dr. Richard Snyder was a researcher at the Highway Safety Institute at the University of Michigan. Following a study on the safety of utility vehicles in crashes, Snyder authored a paper containing findings from the study. The paper concluded that certain utility vehicles, including the Jeep CJ-5, had a high rollover rate when involved in accidents. Jeep Corp. (defendant) was being sued in a consumer class-action lawsuit, and it sought a subpoena compelling Snyder, a nonparty to the lawsuit, to turn over all notes, data, correspondence, and information from the study that led to the paper. Jeep believed that the study would be used against it in the consumer class-action suit. Snyder objected to the subpoena on several grounds, including that as a researcher, he was protected by the First Amendment from testifying against his will. Snyder also argued that forcing him to comply with the subpoena would have a chilling effect on researchers and would interfere with his right of academic freedom. A magistrate granted Snyder’s request to quash the subpoena. Jeep appealed the decision.
Rule of Law
Issue
Holding and Reasoning (Joiner, J.)
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