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Keywords

plaintiffattorneysubpoenastatutemotionsummary judgmentprosecutorgrand juryattorney-client privilege
plaintiffattorneysubpoenastatuteprosecutorgrand jury

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Baylson v. Disciplinary Bd. of Supreme Court of Pennsylvania, 764 F.Supp. 328, 59 USLW 2742

Facts

The plaintiffs, members of the Pennsylvania Bar and federal prosecutors, challenged a state disciplinary rule that required them to obtain judicial approval before subpoenaing attorneys to testify about their clients before a grand jury. This rule was enacted by the Supreme Court of Pennsylvania and was intended to protect attorney-client privilege. The plaintiffs argued that the rule conflicted with federal law and infringed upon their executive duties to investigate criminal wrongdoing. The case involved cross-motions for summary judgment after the district courts in Pennsylvania amended their local rules to exempt themselves from the state rule.

The plaintiffs, members of the Pennsylvania Bar and federal prosecutors, challenged a state disciplinary rule that required them to obtain judicial approval before subpoenaing attorneys to testify about their clients before a grand jury.

Issue

Did the state disciplinary rule requiring judicial approval before subpoenaing attorneys conflict with federal law and impose an unreasonable burden on federal prosecutors?

Did the state disciplinary rule requiring judicial approval before subpoenaing attorneys conflict with federal law and impose an unreasonable burden on federal prosecutors?

Rule

The court applied the principle that local rules must not conflict with federal rules or statutes, and that federal courts have the authority to establish their own procedural rules.

The court applied the principle that local rules must not conflict with federal rules or statutes, and that federal courts have the authority to establish their own procedural rules.

Analysis

The court analyzed the amendments made by the federal district courts in Pennsylvania to their local rules, which exempted them from the state disciplinary rule. It concluded that the state rule imposed an unnecessary burden on federal prosecutors and was inconsistent with federal law, particularly regarding the procedures for grand jury subpoenas. The court emphasized that the local rules were valid and did not require judicial approval for subpoenas directed at attorneys.

The court analyzed the amendments made by the federal district courts in Pennsylvania to their local rules, which exempted them from the state disciplinary rule. It concluded that the state rule imposed an unnecessary burden on federal prosecutors and was inconsistent with federal law, particularly regarding the procedures for grand jury subpoenas.

Conclusion

The court held that the federal prosecutors were entitled to relief from the state disciplinary rule, concluding that the rule was invalid as it conflicted with federal law and imposed an unreasonable burden on the plaintiffs.

The court held that the federal prosecutors were entitled to relief from the state disciplinary rule, concluding that the rule was invalid as it conflicted with federal law and imposed an unreasonable burden on the plaintiffs.

Who won?

The plaintiffs, federal prosecutors, prevailed because the court found that the state rule conflicted with federal law and imposed an unreasonable burden on their duties.

The plaintiffs, federal prosecutors, prevailed because the court found that the state rule conflicted with federal law and imposed an unreasonable burden on their duties.

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