January 1974 Spec. Invest. Grand Jury

2 Citing cases

  1. United States v. Cortese

    614 F.2d 914 (3d Cir. 1980)   Cited 33 times
    Denying release to defense attorney of notes of in camera testimony because “disclosure to attorneys is likely to compromise the policy behind the informer privilege”

    Groendyke Transport, Inc. v. Davis, 406 F.2d 1158 (5th Cir.), cert. denied, 394 U.S. 1012, 89 S.Ct. 1628, 23 L.Ed.2d 39 (1969), held only that the due process clause did not preclude a summary disposition, without oral argument, by the National Labor Relations Board. In re January 1974 Special Investigating Grand Jury, 241 Pa. Super. 246, 361 A.2d 325 (1976), a Pennsylvania court held that in the absence of a compelling state interest, an in camera hearing on the issue of attorney disqualification did not adequately protect a grand jury witness's right to the counsel of his choice. The portion of the case cited by appellees, concerning the ability of the appellant to a "meaningful appeal" indicates only that on remand, a new in camera hearing would have to be held on the record to enable the reviewing court to evaluate the testimony given.

  2. In re Investigation Before Feb.

    563 F.2d 652 (4th Cir. 1977)   Cited 23 times
    Rejecting waiver of conflict of interest by target and non-target grand jury witnesses subject to multiple representation arrangement because no evidence that attorney explained to each client precise nature of actual, rather than potential, conflict and consequences of this conflict, including possible use of confidential facts to sacrifice one client's best interest in order to perform duty to other clients

    Cf. In re Grand Jury Empaneled Jan. 21, 1975, 536 F.2d 1009 (3d Cir. 1976); In re Investigation before April 1975 Grand Jury, 174 U.S.App.D.C. 268, 531 F.2d 600 (1976); and In re Investigating Grand Jury, 241 Pa. Super. 246, 361 A.2d 325 (1976), in all of which cases the facts did not support an order of disqualification which distinguished them from our case. None of these last cases dispute the principle.