Delaware Dept of Finance v. AT&T Inc.
Annotate this CaseThe Delaware Department of Finance served an administrative subpoena on AT&T Inc. to produce records relating to a financial audit. AT&T refused to produce all of the requested records. The Department responded by filing a complaint in the Court of Chancery to enforce the subpoena. AT&T defended by claiming, among other things, that the subpoena exceeded the Department’s authority and was overbroad. The Court of Chancery held that, although the Department validly issued the subpoena, AT&T “met its burden to show that the scope of the subpoena is so expansive that enforcement would constitute an abuse” of the court’s process. The court noted that it had offered the Department the opportunity to supplement the record to explain why the subpoena should be enforced as written, but the Department declined the invitation. The court therefore quashed the subpoena in its entirety. The Department appealed the court’s decision. The Delaware Supreme Court affirmed the Court of Chancery’s judgment. Recognizing that the procedural and substantive aspects of administrative subpoena enforcement were issues of first impression in Delaware, the Supreme Court adopted the procedures and substance followed by the federal courts in administrative subpoena enforcement proceedings. Because the Court announced new procedural and substantive standards governing administrative subpoenas, it allowed the Department to serve a new subpoena on AT&T that complied with the guidance in the Court’s opinion.
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