Gibson Dunn Lawyers Explore Subpoena Enforcement for Law360

Article  |  October 22, 2025

Law360

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Writing for Law360, partner Winston Y. Chan and associates Nicole Butze and Christine Bonomo* delve into a recent ruling by the U.S. District Court for the District of Massachusetts that may provide a new avenue of targeting the issuance of investigative subpoenas. The ruling quashed a U.S. Department of Justice administrative subpoena directed at a hospital. Crucially, in making its ruling, the court relied not only upon the fact that the subpoena contained overbroad requests for information inconsistent with a proper government purpose, but also on public statements made by the executive branch the court found to be indicative of bad faith or improper motive.

In their article, our lawyers provide historical background on investigative subpoenas, the changing legal landscape of investigative subpoena enforcement, and how technology is evolving the legal framework.

*Christine Bonomo is not licensed to practice law in California.