United States Fourth Circuit

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Under Seal v. US, 13-4933

The district court's grant of Doe Jr.'s motion to quash the subpoena requiring him to testify before a grand jury regarding potential federal charges against his father, is reversed and remanded, where: 1) Doe Jr., an adult college student, has not made a strong showing of need for the parent-child privilege; 2) reason and experience do not warrant creation of the privilege in the face of substantial authority to the contrary; and thus, 3) the district court erred in creating a parent-child privilege in this case and excusing Doe Jr. from testifying before the grand jury.

Appellate Information

  • Decided 06/16/2014
  • Published 06/16/2014




  • United States Fourth Circuit


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