Donald Trump v. Mazars USA, LLP, No. 21-5176 (D.C. Cir. 2022)
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The House of Representatives Oversight Committee issued a subpoena to then-President Trump’s personal accounting firm, Mazars USA, LLP. The subpoena sought an array of the President’s personal financial records. President Trump then brought a lawsuit challenging the Committee’s authority to subpoena his financial records.
After the DC Circuit upheld the subpoena, the Supreme Court took up the matter. Trump v. Mazars, 140 S. Ct. 2019 (2020). Since the remand, there have been two developments that potentially affected the shape of the court’s inquiry into the subpoena’s validity. First, President Trump is no longer the sitting President. And second, the Committee’s chairwoman has prepared a detailed explanation of the legislative purposes the subpoena serves and of how the subpoena satisfies the test laid out by the Supreme Court.
The DC Circuit affirmed in part and reversed in part the judgment of the district court. The court agreed with President Trump that the heightened separation-of-powers scrutiny prescribed by the Supreme Court continues to govern in the unique circumstances of this case even though he is no longer the sitting President. However, the court also agreed with the Committee that the court can consider its detailed accounting of the legislative purposes its subpoena serves even though that explanation came after the subpoena’s original issuance.
Thus, the court upheld the Committee’s authority to subpoena certain of President Trump’s financial records in furtherance of the Committee’s enumerated legislative purposes. However, the court wrote it cannot sustain the breadth of the Committee’s subpoena. Rather, in carrying out the Supreme Court’s directive to “insist on a subpoena no broader than reasonably necessary to support Congress’s legislative objective,” the court determined that the Committee’s subpoena must be narrowed in a number of respects.
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