Under Seal v. US: Officers responded to a domestic dispute 911 call at the home occupied by Doe, Doe Jr., and Doe's wife. As a result, they uncovered a large stash of firearms and marijuana, which prompted a federal grand jury to investigate. The Government subpoenaed Doe Jr. to testify before a grand jury about the ownership of the guns and drugs. By that time, Doe Jr.'s parents had separated and he was living with Doe, on whom he was largely dependent financially. Doe Jr. sought to quash the subpoena, invoking a "parent child privilege," arguing that forcing him to testify against his father would irreparably harm their relationship. The district court granted the request and quashed the subpoena.
On appeal, the Fourth Circuit reversed. Although a few district courts have recognized such a privilege, the court noted that every court of appeals (including the Fourth Circuit) to address the issue has rejected it. However, the court found earlier Fourth Circuit cases had not created a "blanket rejection" of the privilege. Nonetheless, the court concluded it was not proper to create one in this case. Doe, Jr. was an adult and admitted that his father would not "cut him off" if he testified against him. In addition, Doe Jr.'s testimony, according to the Government, might not even wind up implicating his father. As a result, Doe Jr. had not shown that recognizing the privilege would promote sufficient important interests that outweigh the need for probative evidence.