United States First Circuit

The district court's order granting the government's motion to compel the Narragansett Indian Tribal Historic Preservation Office (NITHPO) to comply with a subpoena duces tecum is vacated and remanded, where: 1) tribal sovereign immunity did not shield NITHPO from the subpoena; 2) the district court did not abuse its discretion in concluding that the subpoena was reasonable in scope; but 3) a subpoena duces tecum compelling the production of documents to a now-defunct grand jury cannot be enforced by civil contempt sanctions before a successor grand jury.

Appellate Information

• Decided 02/25/2014
• Published 02/25/2014

Judges

• HOWARD

Court

• United States First Circuit

Counsel