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Keywords

subpoenadiscoverytrialmotiontrustcorporationantitrustgrand jury
subpoenadiscoverytrialmotiontrustcorporationantitrustgrand jury

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In re Grand Jury Investigation (General Motors Corp.), 32 F.R.D. 175

Facts

The General Motors Corporation faced an indictment for monopolizing the manufacture and sale of railroad locomotives, which was returned by a grand jury in April 1961. Following this, another grand jury issued subpoenas to several current and former employees of General Motors to investigate alleged perjury before the earlier grand jury. General Motors argued that the subpoenas were an attempt to conduct pre-trial discovery in the antitrust case, as the individuals subpoenaed were likely to be important defense witnesses.

The General Motors Corporation faced an indictment for monopolizing the manufacture and sale of railroad locomotives, which was returned by a grand jury in April 1961. Following this, another grand jury issued subpoenas to several current and former employees of General Motors to investigate alleged perjury before the earlier grand jury. General Motors argued that the subpoenas were an attempt to conduct pre-trial discovery in the antitrust case, as the individuals subpoenaed were likely to be important defense witnesses.

Issue

Whether the grand jury investigation into alleged perjury was a bona fide inquiry or an abuse of process aimed at gathering evidence for the pending antitrust case against General Motors.

Whether the grand jury investigation into alleged perjury was a bona fide inquiry or an abuse of process aimed at gathering evidence for the pending antitrust case against General Motors.

Rule

A grand jury has broad investigatory powers, and evidence obtained during a legitimate investigation can be used for any purpose consistent with the public interest, provided that the investigation is not solely aimed at gathering evidence for a pending case.

A grand jury has broad investigatory powers, and evidence obtained during a legitimate investigation can be used for any purpose consistent with the public interest, provided that the investigation is not solely aimed at gathering evidence for a pending case.

Analysis

The court examined the nature of the grand jury investigation and found that it was a legitimate inquiry into possible perjury, not merely a means to gather evidence for the antitrust case. The court noted that General Motors failed to demonstrate that the investigation's primary purpose was to collect evidence for the antitrust case, and thus, the grand jury's actions were within its rights.

The court examined the nature of the grand jury investigation and found that it was a legitimate inquiry into possible perjury, not merely a means to gather evidence for the antitrust case. The court noted that General Motors failed to demonstrate that the investigation's primary purpose was to collect evidence for the antitrust case, and thus, the grand jury's actions were within its rights.

Conclusion

The court denied General Motors' motion for a protective order, concluding that the grand jury investigation was a bona fide inquiry into perjury and not an abuse of process.

The court denied General Motors' motion for a protective order, concluding that the grand jury investigation was a bona fide inquiry into perjury and not an abuse of process.

Who won?

The government prevailed in this case as the court found that the grand jury investigation was legitimate and not an abuse of process.

The government prevailed in this case as the court found that the grand jury investigation was legitimate and not an abuse of process.

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