Is a subpoena issued against a corporate entity valid?

California, United States of America


The following excerpt is from Connecticut Indemnity Co. v. Superior Court, 23 Cal.4th 807, 3 P.3d 868, 98 Cal.Rptr.2d 221 (Cal. 2000):

The insurers assert that the subpoenas violate the constitutional and statutory privacy rights of their insureds, some of whom are corporate entities. Assuming without deciding that the insureds that are corporate entities have such rights (but see, e.g., Roberts v. Gulf Oil Corp. (1983) 147 Cal.App.3d 770, 791-793, 195 Cal.Rptr. 393 [corporate entities have no privacy rights under art. I, 1 of the Cal. Const.]), and similarly assuming that the insurers have standing to assert the rights of their insureds in this context, we nevertheless conclude that the trial court's ruling upholding the general validity of the subpoenas cannot be reversed on these grounds, because, as the insurers conceded in documents appended to their writ petitions, the trial court has not yet ruled on specific privacy claims and related claims.

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