Sand v. Doe
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The Supreme Court affirmed the district court's order sustaining a subpoena served on a state agency for various categories of information related to a potential transaction, holding that the subpoena was not invalid.
The agency in this case (Agency) and a state institution (Institution) overseen by the Agency contacted Rob Sand, the Iowa Auditor of State (Auditor Sand), to discuss a transaction that was expected to create a multi-billion dollar obligation for the Agency. Auditor Sand requested information on the potential investors involved in the transaction, but the Agency refused to provide the information, asserting that it was confidential. Auditor Sand then served a subpoena on the Agency requesting thirteen categories of documents related to the transaction. The district court entered an order sustaining the subpoena. The Supreme Court affirmed, holding that, even though Auditor Sand was not actually engaged in an audit, the subpoena was valid.
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