## Facts

- The New York County District Attorney opened a state grand jury investigation into possible violations of New York law involving individuals and entities connected to alleged hush-money payments.
- A state grand jury subpoena duces tecum was served on Mazars USA, LLP, the President’s accounting firm, seeking Donald J. Trump’s personal financial and tax records and records of related entities dating from 2011 onward.
- Trump sued in federal court in his personal capacity to enjoin enforcement, asserting Article II and Supremacy Clause-based immunity from state criminal process.
- The district court dismissed on Younger abstention and, alternatively, rejected Trump’s immunity claims on the merits.
- The Second Circuit held Younger abstention inapplicable but affirmed denial of injunctive relief, rejecting both absolute immunity and a proposed heightened-need requirement.

## Issues

1. Whether Article II and the Supremacy Clause categorically bar a state grand jury subpoena directed to a third-party custodian for a sitting President’s private records.
2. If not categorically barred, whether such a subpoena must satisfy a heightened showing of need beyond ordinary grand jury subpoena standards.
3. Whether the President may still assert ordinary objections (e.g., undue burden, overbreadth, bad faith) to the subpoena.

## Decision

- The Supreme Court affirmed the Second Circuit in a 7–2 decision and remanded for further proceedings.
- The Court held that Article II and the Supremacy Clause do not provide categorical immunity from state criminal subpoenas seeking a President’s private papers from a third party.
- The Court held that no heightened-need standard applies merely because the subpoena concerns a sitting President’s private records.
- The Court left open the President’s ability to raise standard subpoena defenses, including claims of undue burden, overbreadth, or bad faith.

## Legal Principles

- A sitting President is subject to judicial process in appropriate circumstances and is not categorically exempt from the duty to provide evidence in criminal proceedings.
- State grand jury subpoenas for a President’s private documents are evaluated under ordinary subpoena rules absent an assertion of executive privilege or a demand for official presidential communications.
- Federal courts may grant relief from a subpoena that is issued in bad faith, is unduly burdensome, or is otherwise improper under generally applicable standards.

## Conclusion

The Court rejected both absolute presidential immunity and a special heightened-need requirement for state grand jury subpoenas seeking private presidential records from third parties, while preserving ordinary avenues to challenge subpoenas that impose improper burdens or reflect bad faith.


Trump v. Vance, 591 U.S. 786 (2020)