Tuesday, December 24, 2013

United States v. Sells Engineering, Inc. case brief

United States v. Sells Engineering, Inc. case brief summary
463 U.S. 418 (1983)

CASE SYNOPSIS
Petitioner United States sought review of a decision of the United States Court of Appeals for the Ninth Circuit, which held that disclosure of grand jury materials to government attorneys and their assistants for use in a civil suit was not permissible absent a court order under Fed. R. Crim. P. 6(e)(3)(C)(i) and that the court below had not correctly applied the particularized-need standard.

CASE FACTS
This case arose when attorneys for the Justice Department attempted to gain access to certain grand jury materials for purposes of pursuing a civil suit. While petitioner United States took the position that its attorneys were entitled to have automatic access to grand jury materials under Fed. R. Crim. P. 6(e)(3)(A)(i), the court below held that access was permissible only pursuant to a court order obtained upon the showing of a particularized need.

DISCUSSION

  • The Court agreed, holding that disclosure as of right under Fed. R. Crim. P. 6(e)(3)(A)(i) applied only to those attorneys who conducted the criminal matters to which the materials pertained. 
  • According to the Court, this conclusion was mandated by the general purposes of grand jury secrecy, by the limited reasons for which government attorneys were granted access to grand jury materials for criminal use, and by the legislative history of Fed. R. Crim. P. 6(e). 
  • The Court also agreed with the trial court's statement that the fact that the grand jury materials were rationally related to the civil suit did not satisfy the particularized need standard for granting court-ordered access.

CONCLUSION
The Court affirmed the trial court's decision based on the Court's holding that government attorneys and their assistants who had not been involved in the grand jury investigation could gain access to grand jury materials only with a court order granted upon the showing of a particularized need.


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