Trump v. Vance

Supreme Court of the United States · 2020 · Criminal Procedure

591 U.S. 786 (2020)

Updated July 27, 2026

Criminal ProcedurePresidential immunityState criminal subpoenasArticle IISupremacy ClauseGrand jury processstate grand jury subpoenasitting President

Facts

The New York County District Attorney's Office, acting on behalf of a grand jury, served a subpoena duces tecum on Mazars USA, LLP, the President's personal accounting firm. The subpoena sought financial records relating to the President and affiliated business organizations, including tax returns and related schedules from 2011 to the present. The President, acting in his personal capacity, sued to block enforcement, arguing that a sitting President enjoys absolute immunity from state criminal process under Article II and the Supremacy Clause. The parties agreed that, for immunity purposes, the subpoena was functionally a subpoena to the President because the papers belonged to him and Mazars was merely the custodian.

Issue

Do Article II and the Supremacy Clause categorically preclude the issuance or enforcement of a state grand jury subpoena seeking a sitting President's private papers? If not, must such a subpoena satisfy a heightened standard of need before it may be enforced?

Rule

A sitting President is not absolutely immune from a state criminal subpoena seeking his private papers, and such a subpoena need not satisfy a heightened standard of need. The President may, however, raise the same objections available to other subpoena recipients under state law, and may also assert subpoena-specific constitutional challenges, including that the subpoena attempts to influence official duties or that compliance would impede the performance of constitutional duties.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

A county grand jury in Illinois serves a subpoena on Lakefront Ledger Group, the personal bookkeeper for a sitting President, seeking invoices and bank reconciliations relating to the President's privately owned apartment buildings in Chicago. The President sues in federal court, arguing that Article II automatically bars any state criminal subpoena directed to his private records while he remains in office.

How should the court rule on the President's categorical immunity claim?

Explanation. The majority held that a sitting President is not absolutely immune from a state criminal subpoena seeking private papers. The fact that the subpoena is served on a third-party custodian does not create categorical immunity where the records are functionally the President's. The President may still raise specific objections, but Article II and the Supremacy Clause do not impose a blanket bar.