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Fed. Rule Crim. Proc. 17 (c) governs the issuance of subpoenas duces tecum in federal criminal proceedings. See Arkansas Louisiana Gas Co. v. Dept. of Public Utilities, 304 U.S. 61, 64 (1938); Ashwander v. TVA, 297 U.S. 288, 346-347 (1936) (Brandeis, J., concurring). Rule 17 (c) provides: 'A subpoena may also command the person to whom it is directed to produce the books, papers, documents or other objects designated therein. The court on motion made promptly may quash or modify the subpoena if compliance would be unreasonable or oppressive. The court may direct that books, papers, documents or objects designated in the subpoena be produced before the court at a time prior to the trial or prior to the time when they are to be offered in evidence and may upon their production permit the books, papers, documents or objects or portions thereof to be inspected by the parties and their attorneys.'
A subpoena for documents may be quashed if their production would be 'unreasonable or oppressive,' but not otherwise. The leading case in the Court interpreting this standard is Bowman Dairy Co. v. United States, 341 U.S. 214 (1951). This case recognized certain fundamental characteristics ...
