28 U.S.C. § 1826

Recalcitrant witnesses

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(a) Whenever a witness in any proceeding before or ancillary to any court or grand jury of the United States refuses without just cause shown to comply with an order of the court to testify or provide other information, including any book, paper, document, record, recording or other material, the court, upon such refusal, or when such refusal is duly brought to its attention, may summarily order his confinement at a suitable place until such time as the witness is willing to give such testimony or provide such information. No period of such confinement shall exceed the life of—(1) the court proceeding, or(2) the term of the grand jury, including extensions,before which such refusal to comply with the court order occurred, but in no event shall such confinement exceed eighteen months.(b) No person confined pursuant to subsection (a) of this section shall be admitted to bail pending the determination of an appeal taken by him from the order for his confinement if it appears that the appeal is frivolous or taken for delay. Any appeal from an order of confinement under this section shall be disposed of as soon as practicable, but not later than thirty days from the filing of such appeal.(c) Whoever escapes or attempts to escape from the custody of any facility or from any place in which or to which he is confined pursuant to this section or section 4243 of title 18, or whoever rescues or attempts to rescue or instigates, aids, or assists the escape or attempt to escape of such a person, shall be subject to imprisonment for not more than three years, or a fine of not more than $10,000, or both.(Added Pub. L. 91–452, title III, § 301(a), Oct. 15, 1970, 84 Stat. 932; amended Pub. L. 98–473, title II, § 1013, Oct. 12, 1984, 98 Stat. 2142.)Editorial NotesAmendments

1984—Subsec. (c). Pub. L. 98–473 added subsec. (c).

Notes of Decisions
Cited in 560 cases (17 in the last 5 years), 1971–2025 · leading case: Gelbard v. United States, 408 U.S. 41 (1972).
Gelbard v. United States, 408 U.S. 41 (1972). · cites it 18× “These cases present challenges to the validity of adjudications of civil contempt, pursuant to 28 U. S. C. § 1826 (a), [1] of witness before federal grand juries *43 who refused to comply with court orders to testify.”
Curtis B. Danning, as Tr. in Bankr. of Fenton, Lavine & Co., a P'ship v. Beau Berlinski Lavine, 572 F.2d 1386 (9th Cir. 1978). · cites it 5× “The second issue is whether or not an order holding defendant a recalcitrant witness under 28 U.S.C. § 1826 for refusing to. answer questions at a deposition may continue in effect after a default judgment has been entered against the defendant.”
In Re Grand Jury Proceedings. In Re Jacqueline Schofield, Witness, 486 F.2d 85 (3rd Cir. 1973). · cites it 8× “See 28 U.S.C. § 1826 . On April 5, 1978 Mrs. Schofield was served with a subpoena commanding her to appear at 4042 United States Courthouse, 9th and Market Streets, Philadelphia, Pa.”
United States v. Harris, 582 F.3d 512 (3rd Cir. 2009). · cites it 6× “Harris asserts that a coercive civil contempt necessarily becomes punitive after the passage of some period of time, and points to the eighteen-month period of confinement established by Congress for recalcitrant witnesses as an appropriate presumptive benchmark.”
Rigby v. Mastro (In Re Mastro), 585 B.R. 587 (9th Cir. BAP 2018). · cites it 7× “In the context of criminal proceedings, the recalcitrant witness statute, 28 U.S.C. § 1826 , which governs grand jury witnesses, emerged as the primary jurisdictional hook.”
In Re Grand Jury Investigation. Appeal of Joseph Braun, Witness, 600 F.2d 420 (3rd Cir. 1979). · cites it 5× “In this appeal we must decide whether appellant’s confinement for civil contempt pursuant to 28 U.S.C. § 1826 (a) exceeds the period of time permissible under the due .”
In Re Grand Jury Proceedings Involving Eve Rosahn, 671 F.2d 690 (2d Cir. 1982). · cites it 6× “Pursuant to 28 U.S.C. § 1826 (a), Judge Cooper ordered that Rosahn be confined until she was willing to provide the items requested, until the expiration of the grand jury’s terms, or until May 9, 1983, whichever should occur first.”
United States v. Thomas Thompson, 925 F.3d 292 (6th Cir. 2019). · cites it 9× “*294 Defendant-Appellant Thomas Thompson appeals the district court's denial of his motion to terminate his civil-contempt sanctions in accordance with 28 U.S.C. § 1826 . Because we determine that Thompson's sanctions do not fall under the eighteen-month incarceration limitation…”
Morrison v. Olson, 487 U.S. 654 (1988). · cites it 2× “The court subsequently ordered that appellees be held in contempt pursuant to 28 U. S. C. § 1826 (a) for continuing to refuse to comply with the subpoenas.”
In the Matter of Grand Jury Empanelled February 14, 1978. Appeal of Nathan Markowitz, 603 F.2d 469 (3rd Cir. 1979). · cites it 4× “be confined pursuant to 28 U.S.C. § 1826 for refusing to disclose the identity of his client and for refusing to produce documents called for by a grand jury subpoena which had been served on him.”
United States v. Rocco Frumento in Re Subpoena to Vito N. Pisciotta, 552 F.2d 534 (3rd Cir. 1977). · cites it 5× “Upon his refusal to testify, the district court entered an order of contempt and confinement pursuant to 28 U.S.C. § 1826 . Although the government contends that the termination of the trial at which he was to testify renders this appeal moot, we disagree.”
In Re: Grand Jury Proceedings of the Special April 2002 Grand Jury, 347 F.3d 197 (7th Cir. 2003). · cites it 6× “3 The Appellant timely filed a notice of appeal, and we have jurisdiction over this appeal pursuant to 28 U.S.C. § 1826 (b), the recalcitrant witness statute.”
— 28 U.S.C. § 1826(a) — 3 cases
In Re Grand Jury Proceedings. In Re Jacqueline Schofield, Witness, 486 F.2d 85 (3rd Cir. 1973). “See 28 U.S.C. § 1826 . On April 5, 1978 Mrs. Schofield was served with a subpoena commanding her to appear at 4042 United States Courthouse, 9th and Market Streets, Philadelphia, Pa.”
Robert Hawthorne, Inc. v. Dir. of Internal Revenue, 406 F. Supp. 1098 (E.D. Pa. 1976).
United States v. Mark Lawrence Alter, 482 F.2d 1016 (9th Cir. 1973).
— 28 U.S.C. § 1826(a)(1) — 1 case
— 28 U.S.C. § 1826(b) — 3 cases
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