- Congress's attempt to subpoena Trump's personal records
- Introduced a four-part framework for congressional subpoenas for personal, non-official records of a sitting President:
- Availability of Other Sources
- Congress may not demand the President's information if other sources could reasonably provide the sought information.
- The President cannot be used "merely as a case study."
- Scope of the Subpoena
- The subpoena must be no broader than reasonably necessary to support Congress's legislative objective.
- Evidence of Legislative Purpose
- Congress must clearly identify its aims and explain why the President's specific information will advance the consideration of that legislation.
- Courts must scrutinize this justification.
- Burden on the President
- Courts must assess the burden that the subpoena imposes on the President's time and attention.