Trump v. Mazars USA

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Trump v. Mazars USA, LLP, 39 F.4th 774, 779 (D.C. Cir. 2022), held as follows on Donald Trump's challenge to a congressional subpoena for his personal financial records:

we uphold the Committee's authority to subpoena certain of President Trump's financial records in furtherance of the Committee's enumerated legislative purposes. But we 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," id. at 2036, we determine for the following reasons that the Committee's subpoena must be narrowed in a number of respects.

While President, Trump declined to emasculate himself by transferring all his assets to a blind trust, as his predecessors had done.

The Committee lacks an adequate alternative source to inform its consideration of that kind of emoluments-related legislation. Among recent Presidents, according to the Committee, only President Trump declined to divest himself of his business interests and place his assets in an independent blind trust, thus failing to separate himself from emoluments received during his tenure. And the Committee has concluded that President Trump's "complex and opaque financial holdings" were "unprecedented" among modern Presidents. First Maloney Mem. 3. In view of the apparent volume of spending by government actors at President Trump's properties while he was in office, the Committee alleges that the "financial disclosure laws have never been tested in this way by a president." Id. at 38.

Trump v. Mazars USA, LLP, 39 F.4th 774, 797 (D.C. Cir. 2022).