Roe v. United States

How later courts describe this case

• recognizing that “[f]ee information may be sought as evidence of unexplained wealth which may have been derived from criminal activity”
• government not required to make preliminary showing of need prior to enforcement of grand jury subpoena served on attorney whose client is the unindicted target of grand jury investigation
• prior to indictment, adversary proceeding not initiated against grand jury target; Sixth Amendment right to counsel therefore did not attach and so did not prevent service of grand jury subpoena on target’s attorney
• rejecting requirement to show in both preand post-indictment contexts
• discussing an unpublished Fourth Circuit opinion addressing Harvey
• “[i]n order to establish improper prejudgment of a case, it must appear to ‘a disinterested observer ... that [the agency] has in some measure adjudged the facts as well as the law of a particular case in advance of hearing it’” (citations omitted)