Kennebec Log Driving Co. v. United States

18 U.S.C. § 3500(d) and Rule 33 cited as separate bases for imposing sanction of new trial for government failure to comply with Jencks Act | “public image considerations” may be “a sufficient basis for discharging an employee,” particularly where an agency has a special “need to maintain public confidence in its image of integrity” | unintentional, nonnegligent loss of grand jury minutes would not justify sanctions; remanded | where the loss of evidence is negligent, a court is directed to ask whether the defendant is so greatly prejudiced by the unavailability at trial such that sanctions ought to be imposed