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United States v. Baggot, 463 U.S. 476 (1983)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
United States v. Baggot, 463 U.S. 476 (1983)
United States v. Baggot No. 81-1938 Argued March 2, 1983 Decided June 30, 1983 463 U.S. 476
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
THE SEVENTH CIRCUIT
Syllabus
Federal Rule of Criminal Procedure 6(e)(3)(C)(i) permits disclosure otherwise prohibited by Rule 6 of matters occurring before a grand jury "when so directed by a court preliminarily to or in connection with a judicial proceeding." Respondent was the target of a grand jury investigation of certain commodity futures transactions. He was never indicted, but, after plea negotiations, pleaded guilty to misdemeanor violations of the Commodity Exchange Act. Thereafter, the Government filed a motion under Rule 6(e)(3)(C)(i) for disclosure of grand jury transcripts and documents to the Internal Revenue Service (IRS) for use in an audit to determine respondent’s civil income tax liability. While holding that disclosure was not authorized by Rule 6(e)(3)(C)(i), the District Court nevertheless allowed disclosure under its "general supervisory powers over the grand jury." The Court of Appeals reversed, agreeing that no disclosure is available under Rule 6(e)(3)(C)(i), but holding that the District Court erred in granting disclosure under "general supervisory powers."
Held: The IRS’s civil tax audit is not "preliminar[y] to or in connection with a judicial proceeding" within the meaning of Rule 6(e)(3)(C)(i), and hence no disclosure is available under that Rule. The Rule contemplates only uses related fairly directly to some identifiable litigation, pending or anticipated. It is not enough to show that some litigation may emerge from the matter in which the material is to be used. The focus is on the actual use to be made of the material. It follows that disclosure is not appropriate for use here in the IRS’s audit, the purpose of which is not to prepare for or conduct litigation, but to assess the amount of tax liability through administrative channels. The fact that, if the audit discloses a deficiency, respondent may seek judicial redress in a redetermination proceeding in the Tax Court or in a refund action in the Court of Claims or a district court, without more, does not mean that the Government’s action is "preliminar[y] to . . . a judicial proceeding." Pp. 478-483.
662 F.2d 1232, affirmed.
BRENNAN, J., delivered the opinion of the Court, in which WHITE, MARSHALL, BLACKMUN, POWELL, REHNQUIST STEVENS, and O’CONNOR, JJ., joined. BURGER, C.J., filed a dissenting opinion, post, p. 483.
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Chicago: U.S. Supreme Court, "Syllabus," United States v. Baggot, 463 U.S. 476 (1983) in 463 U.S. 476 463 U.S. 477. Original Sources, accessed October 10, 2024, http://www.originalsources.com/Document.aspx?DocID=CS33CNBXGRPESLR.
MLA: U.S. Supreme Court. "Syllabus." United States v. Baggot, 463 U.S. 476 (1983), in 463 U.S. 476, page 463 U.S. 477. Original Sources. 10 Oct. 2024. http://www.originalsources.com/Document.aspx?DocID=CS33CNBXGRPESLR.
Harvard: U.S. Supreme Court, 'Syllabus' in United States v. Baggot, 463 U.S. 476 (1983). cited in 1983, 463 U.S. 476, pp.463 U.S. 477. Original Sources, retrieved 10 October 2024, from http://www.originalsources.com/Document.aspx?DocID=CS33CNBXGRPESLR.
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