§ 4.2.19 Subpoenas
“Subpoenas are not search warrants” because “they involve a different level of intrusion on a person’s privacy,” even when they are served at the same time as a search warrant. In re Grand Jury Subpoenas Dated Dec. 10, 1987, 926 F.2d 847, 854 (9th Cir. 1991) (“Rule 17 of the Federal Rules of Criminal Procedure provides that a grand jury may issue a subpoena.”). See also State v. Mixton, 250 Ariz. 282, 478 P.3d 1227 (2021) (Fourth...
