RANDY BRASWELL, PETITIONER V. UNITED STATES OF AMERICA No. 87-3 In the Supreme Court of the United States October Term, 1987 On Writ of Certiorari to the United States Court of Appeals for the Fifth Circuit Brief for the United States TABLE OF CONTENTS Question Presented Opinion below Jurisdiction Statement Summary of argument Argument: The custodian of a corporation's records may not resist a subpoena for those records on the ground that his act of producing them would violate his personal privilege against compulsory self-incrimination A. The collective entity rule remains valid and applies to this case 1. The collective entity rule is an important and well-established principle of Fifth Amendment law 2. The rationale supporting the collective entity rule remains sound and applies fully to cases in which the Fifth Amendment claim is based on the incriminatory character of an act of production B. Although this Court should not reach two other issues discussed in petitioner's brief, petitioner's analysis of those issues is flawed 1. Petitioner's claim that he would be incriminated by the act of producing corporate documents improperly rests on the contents of those documents 2. Petitioner's claim that a court may not require that someone else be designated to produce the corporate documents is incorrect Conclusion OPINION BELOW The opinion of the court of appeals (J.A. 19-25) is reported at 814 F.2d 190. JURISDICTION The judgment of the court of appeals was entered on March 31, 1987. A suggestion for rehearing en banc, which the panel treated as a petition for rehearing, was denied on April 30, 1987 (Pet. App. 4a-5a). The petition for a writ of certiorari was filed on June 26, 1987, and was granted on October 5, 1987. The jurisdiction of this Court rests on 28 U.S.C. 1254(1). QUESTIONS PRESENTED Whether the custodian of a corporation's records may resist a subpoena for those records on the ground that his act of producing them would violate his personal privilege against compulsory self-incrimination. STATEMENT 1. Petitioner is the president and sole shareholder of Worldwide Machinery Sales, Inc., and Worldwide Purchasing, Inc. (J.A. 19). From 1965 to 1980, petitioner conducted his business, which includes the sale and purchase of equipment, oil and gas interests, and land and timber, as a sole proprietorship. In 1980, he incorporated Worldwide Machinery, a Mississippi corporation, and began conducting his business through that entity. In 1981, he incorporated Worldwide Purchasing, also a Mississippi corporation, out of concern that the name "Worldwide Machinery" did not adequately reflect the variety of his pursuits. J.A. 20. Petitioner funded Worldwide Purchasing with the stock he held in Worldwide Machinery, and he retained ownership of 100 percent of the stock of Worldwide Purchasing. Both companies are active corporations, maintaining a current status with the State of Mississippi, keeping current corporate books and records, including financial records and minutes, and filing corporate tax returns. J.A. 20. The corporations employ at least one person other than petitioner -- a secretary, who is petitioner's sister-in-law (Pet. Br. 5). Petitioner, his wife, and his mother are directors of both corporations. According to petitioner, however, neither his wife nor his mother has any authority over the business affairs of the corporations, although they are secretary-treasurer and vice-president of the corporations, respectively (J.A. 20-21). 2. On August 20, 1986, a federal grand jury sitting in the Southern District of Mississippi subpoenaed the books and records of Worldwide Purchasing and Worldwide Machinery. /1/ The subpoena permitted delivery of the subpoenaed documents to the agent serving the subpoena (J.A. 21) and thus did not require petitioner to testify. Petitioner moved to quash the subpoena, arguing that the act of producing the subpoenaed records would incriminate him in violation of his Fifth Amendment privilege against compulsory self-incrimination. The district court denied the motion (J.A. 10-14, 15-16). Relying on the Fifth Circuit's decision in In re Grand Jury Subpoena (Lincoln), 767 F.2d 1130 (1985), the court held (J.A. 12-14) that the custodian of records of a collective entity, such as a corporation, has no Fifth Amendment privilege to refuse to comply with a subpoena for those records. The court rejected petitioner's contention that the so-called "collective entity rule" should not apply here because petitioner's business was a purported one-man operation (J.A. 12). Petitioner subsequently appeared before the grand jury but refused to produce the subpoenaed documents. On motion of the government, the district court held petitioner in contempt and ordered him committed to the custody of the United States Marshal until he complied with the court's order (J.A. 17-18). The district court, however, stayed the commitment pending appeal (Pet. App. 12a). 3. The court of appeals affirmed (J.A. 19-25). The court followed its prior decision in Lincoln, although it noted (J.A. 24-25) the existence of a conflict among the circuits on the issue of whether a custodian of corporate records may resist a subpoena for those records on Fifth Amendment grounds. Relying on Bellis v. United States, 417 U.S. 85, 100 (1974), the court rejected petitioner's argument based on the size of his corporations. The court stated (J.A. 23) that "corporations, no matter how small, are collective entities." On June 10, 1987, Justice White entered an order staying the mandate of the court of appeals pending the disposition by this Court of the petition for certiorari (Pet. App. 1a). SUMMARY OF ARGUMENT A. Petitioner explicitly disclaims any argument that the Fifth Amendment protects against disclosure of the contents of corporate records. He argues, however, that an individual in possession of corporate documents may interpose his own personal Fifth Amendment privilege to resist producing those documents on the ground that the individual's act of production would be both incriminatory and testimonial in nature. Petitioner asks this Court to overrule the "collective entity rule," which holds that a custodian may not block access to corporate documents on the basis of his personal privilege. That rule was established in 1911 and has been reaffirmed repeatedly, most recently in Fisher v. United States, 425 U.S. 391 (1976). The collective entity rule, which is of enormous importance in the investigation and prosecution of white-collar crime, complements the undisputed principle that the corporation itself has no privilege against incriminating itself or its officers or employees. The collective entity rule is as valid today as it has been throughout the past 75 years. It precludes Fifth Amendment privilege claims based on the allegedly incriminating nature of the act of producing documents as well as Fifth Amendment privilege claims based on the allegedly incriminating contents of the documents. The rule is best explained by the recognition, prominent in this Court's past decisions, that a corporate custodian acts as the agent of the corporation and not as an individual when he produces documents; his freedom from compelled self-incrimination does not protect him against incrimination by the corporation's act of producing documents. Consistent with that rationale, the government may be precluded from treating the act of production as an individual rather than a corporate act in any subsequent proceeding. The government may, however, make use -- even against the corporate custodian -- of the corporation's act of production to show the authenticity of the documents, their existence, and their possession by the corporation. B. This Court should not reach two issues discussed in petitioner's brief but not decided by the courts below: whether the "facts and circumstances" of this particular case show a realistic likelihood of incrimination through the act of production and, if so, whether it would be permissible to require the corporations to find or appoint someone other than petitioner to produce the records. If, as we contend, the court of appeals correctly held that the collective entity rule precludes petitioner from asserting any personal Fifth Amendment privilege in this case, then this Court need not reach those two issues in order to affirm. If this Court were instead to disagree with the court of appeals, then the issues discussed in petitioner's brief would become relevant, but those issues should in that event be addressed in the first instance by the lower courts on remand, not by this Court. Although we do not believe that this Court should address those two issues, we do note some critical flaws in petitioner's analysis of them. Petitioner's claim that he would be incriminated by the act of producing corporate documents improperly rests on the contents of those documents and not on what the act of producing them would tell the government. And petitioner's claim that a court may not require that someone else be designated to produce the corporate documents is contrary to the view of every federal court of appeals and would in effect overturn the rule that corporations have no Fifth Amendment privilege against compulsory self-incrimination. ARGUMENT THE CUSTODIAN OF A CORPORATION'S RECORDS MAY NOT RESIST A SUBPOENA FOR THOSE RECORDS ON THE GROUND THAT HIS ACT OF PRODUCING THEM WOULD VIOLATE HIS PERSONAL PRIVILEGE AGAINST COMPULSORY SELF-INCRIMINATION The issue in this case is whether the Fifth Amendment protects petitioner from being required to produce the records of Worldwide Purchasing and Worldwide Machinery. Petitioner explicitly "does not claim that the Fifth Amendment protects against the disclosure of the contents of (the) records" of Worldwide Purchasing and Worldwide Machinery (Pet. Br. 7; see also id. at 12). Such a claim would be unavailing in view of this Court's decisions holding that the Fifth Amendment does not protect the contents of business records voluntarily prepared before the subpoena for them was issued. United States v. Doe, 465 U.S. 605 (1984); Fisher v. United States, 425 U.S. 391 (1976). Rather, petitioner argues that the Fifth Amendment forbids compelling his act of producing the subpoenaed documents because that act would incriminate him, in that it would implicitly acknowledge the existence of the subpoenaed documents, their authenticity, and his possession and control of them. That argument, however, is foreclosed by this Court's decisions that have repeatedly held that a custodian of corporate records such as petitioner has no Fifth Amendment privilege to refuse to comply with a subpoena for those records. Petitioner suggests that this Court has implicitly abandoned that line of authority, and that in any event that line of authority does not extend to a case in which the basis of the Fifth Amendment claim is that the act of production is self-incriminatory. Neither suggestion is convincing. A. The Collective Entity Rule Remains Valid and Applies to this Case 1. The Collective Entity Rule Is an Important and Well-Established Principle of Fifth Amendment Law a. Petitioner argues that a custodian of corporate documents may refuse to produce those documents on the ground that the testimonal component of the act of production would incriminate him. This Court, however, has repeatedly upheld subpoenas against the custodians of documents belonging to corporations or other collective entities. The Court has done so in the face of claims that the documents will incriminate the custodian, and "despite the fact that producing the documents tacitly admits their existence and their location in the hands of their possessor." Fisher, 425 U.S. at 411-412. That "collective entity rule" applies directly to this case, for the Court has stated in the clearest possible terms that it applies to corporations such as Worldwide Purchasing and Worldwide Machinery: "It is well settled that no privilege can be claimed by the custodian of corporate records, regardless of how small the corporation may be." Bellis v. United States, 417 U.S. 85, 100 (1974); see Grant v. United States, 227 U.S. 74 (1913) (applying collective entity rule to records of a defunct corporation that at all times had only one shareholder). /2/ This Court has often stated the collective entity rule in terms similar to those employed in Bellis: "no privilege can be claimed by the custodian of corporate records" (417 U.S. at 100). Petitioner, however, seeks to engraft onto all such statements a limiting construction under which they mean only that no privilege can be claimed by the custodian of corporate records as to the contents of those records. If he succeeds, there will be nothing left of the collective entity rule, for Fisher and Doe make it clear that, entirely apart from the collective entity rule, no one may claim a privilege as to the contents of voluntarily prepared business records. Thus, by arguing that the "act-of-production" doctrine should be extended to corporate custodians, petitioner is in effect asking this Court to overrule the collective entity rule altogether. The step that petitioner asks this Court to take is a large one indeed. The collective entity rule dates back to 1911, when the Court recognized the rule in the seminal case of Wilson v. United States, 221 U.S. 361 (1911). Since that time, the Court has reaffirmed the collective entity rule "time and again" (Fisher, 425 U.S. at 411). The predicate for the collective entity rule is the even older rule that the privilege against compelled self-incrimination extends only to natural persons, not to corporations. That rule, first articulated in Hale v. Henkel, 201 U.S. 43 (1986), is as settled as any principle of Fifth Amendment law. See Bellis, 417 U.S. at 90; United States v. Kordel, 397 U.A. 1, 7 & n.9 (1970); George Campbell Painting Corp. v. Reid, 392 U.S. 286, 288-289 (1968); Wheeler v. United States, 226 U.S. 478, 489 (1913). /3/ Because a corporation cannot invoke the privilege on its own behalf, and because the privilege may be involved only by the party who is subject to incrimination (Hale v. Henkel, 201 U.S. at 69-70), it is clear that a corporation cannot invoke the Fifth Amendment to protect against the incrimination of any natural person, including the corporation's officers and employees. What remained to be decided after Hale was whether an individual could refuse to produce corporate records on the ground that he would incriminate himself. In Wilson and its companion case, Dreier v. United States, 221 U.S. 394 (1911), the Court held that he could not. The Court stated in Wilson, 221 U.S. at 384: "The appellant held the corporate books and records subject to the corporate duty. If the corporation were guilty of misconduct, he could not withhold its books to save it; and if he were implicated in the violations of law, he could not withhold the books to protect himself from the effect of their disclosures." Summarizing Wilson, the Court added in Dreier (221 U.S. at 400): "Dreier was not entitled to refuse the production of the corporate records. By virtue of the fact that they were the documents of the corporation in his custody, and not his private papers, he was under obligation to produce them when called for by proper process." The collective entity rule has become firmly entrenched in this Court's jurisprudence. Since Wilson, this Court has reaffirmed the rule on at least 11 occasions, and not a single Justice has questioned the rule. /4/ As recently as 1976 -- in the very case that petitioner claims demonstrates that "(a)any determination of the availability of a Fifth Amendment privilege which is a function of the entity whose records are sought * * * is simply unworkable" (Pet. Br. 39-40) -- the Court reaffirmed that "neither a (collective entity) nor the individual (representatives of the entity) are shielded from compelled production of * * * records (of the entity) on self-incrimination grounds" (Fisher, 425 U.S. at 408). /5/ b. Besides being well established, the collective entity rule is extremely inportant. Grand jury subpoenas for corporate documents provide invaluable assistance in the detection and prosecution of whitecollar crime, which has been called "the most serious and all pervasive crime problem in America today." /6/ As this Court has recognized, "(t)he greater portion of evidence of wrongdoing by an organization or its representatives is usually to be found in the official records and documents of that organization." White, 322 U.S. at 700. "Were the cloak of the privilege to be thrown around these impersonal records and documents, effective enforcement of many federal and state laws would be impossible" (ibid.; accord Bellis, 417 U.S. at 90-91). "If * * * an officer or employe of a corporation * * * could refuse to produce the (corporation's) books and documents * * * it would result in the failure of a large number of cases where the illegal combination was determinable only upon the examination of such papers" (Hale, 201 U.S. at 74). /7/ Detection of white-collar crime often depends not only on obtaining access to documents, but also on comparing large numbers of facially innocuous documents to discern a pattern that gives rise to an inference of illegal behavior. /8/ Accordingly, broad subpoenas for large and sometimes general categories of documents -- exactly the kind of subpoenas that courts have been reluctant to enforce over a claim of act-of-production privilege -- are often the only means by which crime can be detected. /9/ In sum, the abolition of the collective entity rule, and the recogniztion of a privilege on the part of custodians of corporate documents, would have a devastating impact on one of the most important areas of law enforcement. c. In seeking to justify abolition of the collective entity rule, a few commentators and one court have asserted -- contrary to the foregoing analysis -- that the recognition of an act-of-production privilege for corporate custodians "would not * * * markedly frustrate the Government's investigation of possible criminal offenses or its enforcement of criminal provisions" (In re Sealed Case, 832 F.2d 1268, 1282 (D.C. Cir. 1987), (footnote omitted)). Petitioner briefly echoes this theme (Pet. Br. 35-36). The argument is based on two premises: that the government's ability to obtain the corporate records by immunizing the custodian's act of production under the federal immunity statute, 18 U.S.C. 6002-6003, is a fully adequate substitute for the unimmunized compulsion of production, and that the government's ability to obtain the corporate records merely by addressing the subpoena to the corporation also serves all of the government's legitimate interests (see In re Sealed Case, 832 F.2d at 1281-1282). /10/ Both premises founder against the reality of subpoena practice. Grants of immunity could have a severe impact on the government's ability to detect and prosecute corporate crime. Act-of-production immunity might not be troublesome if it meant only that the government could not make evidentiary use of the custodian's tacit acknowledgment that the documents produced under a grant of immunity existed, were in his possession, and were the documents described in the subpoena. Use immunity, however, normally involves a much more sweeping prohibition: it bars the government from making any derivative use of immunized testimony in its investigation of crime. Kastigar v. United States, 406 U.S. 441, 460 (1972); see also Pillsbury Co. v. Conboy, 459 U.S. 248, 255 (1983). Because of the difficulties of proving at trial that immunized testimonial conduct was not directly or indirectly used in the investigation, it has been noted that "the prohibition against derivative use may have disastrous consequences for the prosecution" (Alito, Documents and the Privilege Against Self-Incrimination, 48 U. Pitt. L. Rev. 27, 63 (1986)) and that "this alternative may preclude prosecution of the claimant" (Heidt, supra, 49 Mo. L. Rev. at 482 n.172). See also Mosteller, Simplifying Subpoena Law: Taking the Fifth Amendment Seriously, 73 Va. L. Rev. 1, 40 (1987) (arguing that act-of-production immunity "is broad and far-reaching"). For example, when an immunized witness produces documents, but the documents do not show on their face that they are the documents described in the subpoena, the witness has made a tacit statement concerning the nature of the documents. That "statement" may be a valuable investigative lead. /11/ Yet, if the corporate representative must be granted act-of-production immunity, including derivative immunity, in exchange for compelling him to produce corporate documents, the government may be foreclosed from following up on that investigative lead unless it is willing to forgo using subsequently uncovered evidence against the immunized witness. See Alito, supra, 48 U. Pitt. L. Rev. at 63-64. As a consequence, the price of obtaining corporate records, when the records are in the possession of a corporate representative who is suspected of involvement in criminal conduct, may be to exempt the corporate representative from prosecution, or at least to make investigation and prosecution of such a representative even more difficult than it has been in the past. /12/ The other argument sometimes advanced to show that abolition of the collective entity rule will not harm the investigation of crime is that the government can always obtain corporate records merely by addressing the subpoena to the corporation rather than to an individual because the corporation "must find some means by which to comply because no Fifth Amendment defense is available to it (In re Sealed Case, 832 F.2d at 1282 n.9; see also id. at 1278). Therefore, the argument runs, the government always has a means to obtain corporate records without granting anyone use immunity -- it need only allow the corporation to select the individual who will physically produce them. Although we agree with the unanimous view of the courts of appeals that this is a constitutionally valid way for the government to obtain records, /13/ we do not share the District of Columbia Circuit's optimism that it will always be an effective way. Consider, for example, the case of a defunct corporation (or a corporation disbanded in anticipation of or in response to a subpoena). It generally will not be possible to address a subpoena to that disbanded legal entity, as opposed to some natural person holding its records. Yet the traditional collective entity rule permits the government to obtain corporate records in that situation by directing the subpoena to the individual who had been the corporation's sole shareholder. Bellis, 417 U.S. at 88 ("no Fifth Amendment privilege could be claimed with respect to corporate records even though the corporation had previously been dissolved.") Suppose, however, that that rule were abolished, as petitioner suggests it should be. The government would no longer be able to address the subpoena to the custodian of records of the defunct corporation. And, if a subpoena were addressed instead to the (non-existent) corporation and were disobeyed, threats of contempt could not induce compliance with the subpoena, for the corporation would have no assets against which to impose coercive fines and no officers to threaten with incarceration. If the collective entity rule were replaced with a rule that required the government to address its subpoenas for corporate documents to the entity itself rather than its custodian of records, it would surely become a standard ploy to disband small corporations used for shady dealings as a way of protecting the records of those corporations against the grand jury's legitimate exercise of its subpoena power. A variation on the same theme is the argument that the government should subpoena corporate records from an individual but should find one who is not subject to potential incrimination. That, too, is not a practical answer. It is often the case that only the subjects of an investigation know the location of the corporate records most pertinent to the criminal investigation. In the case of small entities, every qualified custodian may be subject to potential criminal liability, or the person subject to potential liability may try to exclude his colleagues from any access to the records (see, e.g., Bellis, 417 U.S. at 99). Petitioner argues that a corporate employee asserting his Fifth Amendment privilege should have no duty to assist an appointed corporate custodian in locating the corporate records that are the subject of the subpoena (Pet. Br. 47). If that rule is adopted, the threat of a contempt sanction against corporate employees for failing to comply with subpoenas to the corporation will be meaningless. In that setting, it is not difficult to imagine how often incriminating documents will lose their way between the corporation's files and the grand jury room. Thus, the proposed substitutes for the collective entity rule are inadequate. In spite of petitioner's claim to the contrary, abolition of the collective entity rule, as petitioner proposes, would have a devastating impact on enforcement of the laws against white-collar crime. Petitioner has offered no reason to doubt the truth of this Court's observation in 1974 that "recognition of the individual's claim of privilege with respect to the financial records of the organization" would "largely frustrate legitimate governmental regulation of such organizations" (Bellis, 417 U.S. at 90). 2. The Rationale Supporting the Collective Entity Rule Remains Sound and Applies Fully to Cases in Which the Fifth Amendment Claim Is Based on the Incriminatory Character of an Act of Production Petitioner challenges the reasoning that has supported the collective entity rule through the years (see Pet. Br. 31-40), concluding that each justification provided for the rule either is wrong or is inconsistent with the Court's Fifth Amendment analysis in Fisher and Doe. We submit that the reasons this Court has given to support the collective entity rule remains sound, and that there is nothing in either Fisher or Doe that undercuts them. a. The Court has set forth four related justifications for the collective entity rule. First, the Court has stated that a custodian of corporate documents is deemed to waive his Fifth Amendment privilege by accepting custody of the corporation's property. See Curcio, 354 U.S. at 124-125 ("By accepting custodianship of records (the custodian) 'has voluntarily assumed a duty which overrides his claim of privilege' * * * with respect to the production of the records themselves."); Wilson, 221 U.S. at 380. Second, as we have touched on above, the Court has reasoned that the corporation, having no privilege of its own, should not be given a de facto privilege by recognizing a personal privilege in the custodian of its documents. See Bellis, 417 U.S. at 90; see also Wilson, 221 U.S. at 384-385 ("The reserved power of visitation would seriously be embarrassed, if not wholly defeated in its effective exercise, if guilty officers could refuse inspection of the records and papers of the corporation."). Third, the Court has noted that the collective entity rule is essential to law enforcement and has only a minimal impact on Fifth Amendment values. As the Court explained in White, 322 U.S. at 700, (t)he scope and nature of the economic activities of incorporated and unincorporated organizations and their representatives demand that the constitutional power of the federal and state governments to regulate those activities be correspondingly effective. * * * The framers of the constitutional guarantee against compulsory self-disclosure, who were interested primarily in protecting individual civil liberties, cannot be said to have intended the privilege to be available to protect economic or other interests of such organizations so as to nullify appropriate governmental regulations. See also Bellis, 417 U.S. at 90-91; 8 J. Wigmore, Evidence Section 2259b, at 360-361 (J. McNaughton rev. ed. 1961); Alito, supra, 48 U. Pitt. L. Rev. at 69-70; Meltzer, Required Records, the McCarran Act, and the Privilege Against Self-Incrimination, 18 U. Chi. L. Rev. 687, 705-706 (1951); Developments in the Law -- Corporate Crime: Regulating Corporate Behavior Through Criminal Sanctions, 92 Harv. L. Rev. 1227, 1283 (1979); cf. Note, supra, 54 Fordham L. Rev. at 950-951 & nn.118 & 120. Fourth, and most impotant, the Court has pointed out that the individual who produces corporate documents on behalf of the corporation does not do so in his individual capacity, but rather as the agent of the corporation, so that the act of production, if incriminatory, constitutes incrimination of the individual by the corporation, rather than incrimination of the individual by his own words or deeds. /14/ As this Court explained in White, 322 U.S. at 699, individuals, when acting as representatives of a collective group, cannot be said to be exercising their personal rights and duties nor to be entitled to their purely personal privileges. Rather they assume the rights, duties and privileges of the artificial entity or association of which they are agents or officers and they are bound by its obligations. In their official capacity, therefore, they have no privilege against self-incrimination. And the official records and documents of the organization that are held by them in a representative rather than in a personal capacity cannot be the subject of the personal privilege against self-incrimination, even though production of the papers might tend to incriminate them personally. Since the decision in White, that rationale for the rule has been reiterated on several occasions. See Curcio, 354 U.S. at 123; Bellis, 417 U.S. at 90; Fisher, 425 U.S. at 430 n.9 (Brennan, J., concurring in the judgment). Taken together, these justifications for the collective entity rule can be summarized as follows: A corporation called on to turn over documents must act through a human being. Necessarily, then, an individual who has undertaken to act for the corporation is cloaked with the corporate mantle when he performs the act of producing documents. The corporation may be compelled to produce documents notwithstanding any incrimination of the corporation or any individual. Therefore, when an individual acts as the agent of the corporation -- as he does whenever he produces corporate documents -- it is the corporation and not the individual who is turning over the documents, and there is no privilege available for either the individual or the corporation to claim. b. Petitioner attempts to distinguish the cases announcing and reaffirming the collective entity rule by arguing that the collective entity rule never applied to the testimonial aspects of the act of producing corporate records. If petitioner means to suggest that the cases announcing the collective entity rule would have been decided differently if the records custodians had sought to rely on the incriminating content of their act of producing documents, rather than the incriminating contents of the documents themselves, petitioner is mistaken. In the first place, this Court's opinions stating the collective entity rule have regularly expressed the rule as prohibiting the custodian of records from invoking the Fifth Amendment as a basis for resisting a subpoena, not just as a restatement of the principle that the contents of the documents give rise to no Fifth Amendment claim. /15/ To suggest that the Court would have been impressed in those cases with an "act-of-production" argument that was not made is to ignore the unequivocal terms in which the Court repeatedly rejected the Fifth Amendment argument that was made. In all of those cases, the Court assumed that, if the records were personal rather than corporate records, the custodian would have a valid claim under the Fifth Amendment's proscription against compulsory self-incrimination; yet the Court in each case affirmed the right of the government to compel that incrimination in light of the corporate status of the records and the collective entity rule. /16/ In the second place, this Court reiterated the collective entity rule as accepted doctrine throughout the opinions in Curcio and Fisher, cases in which the Court carefully focused on the potential of testimonial incrimation through the compelled act of production. /17/ Petitioner's assertion that "this Court has never addressed the conflict between the Government's right to records, and the right of a custodian * * * not to incriminate himself through his act of producing them" (Pet. Br. 31) is thus entirely incorrect. The Court in Curcio and Fisher fully understood that the act of production can incriminate the custodian of records, and the Court made it clear that the custodian must produce the documents anyway. The real question in this case is not whether the collective entity rule as framed before Fisher and Doe operated to bar an assertion of an act-of-production privilege: as we have shown, it plainly did. The real question in this case is whether Fisher and Doe undermined the prior cases announcing the collective entity rule. We submit that they did not. Fisher involved the act-of-production privilege of an individual taxpayer, and Doe involved the act-of-production privilege of a sole proprietor, whom the Court treated as having the same rights as an individual. Neither case involved an attempt to compel the representative of a collective entity to produce that entity's records. Nonetheless, the Court in Fisher referred to the collective entity rule as accepted doctrine, and the Court said nothing in Doe to suggest any disapproval or questioning of the rule. /18/ In light of this Court's simultaneous approval of both the act-of-production doctrine and the collective entity rule in Fisher, petitioner's position must be that there is some logical inconsistency between the two that escaped the Court's notice at the time. We see no such inconsistency. In Fisher, this Court rejected the argument that an individual may decline to produce his voluntarily prepared business records on the ground that the contents of those records might incriminate him. Because the disclosure of the contents of such records is not testimonial, the Court held, the privilege against compulsory self-incrimination provides no protection against such disclosure. When an individual is called on to produce such records, the Court noted, the only possible source for a claim of privilege is the testimonial aspect of the act of producing the documents. Thus, the Fisher Court held that, when a subpoena seeks the business records of an individual or a sole proprietorship, the Court will not inquire into the contents of the records, but will instead inquire whether the act of production has testimonial, incriminatory aspects (425 U.S. at 410; see also Doe, 465 U.S. at 612-613). Fisher's rejection of the proposition that the contents of business records can ever be the subject of a valid Fifth Amendment claim was a watershed holding. But the Court's recognition of the act-of-production doctrine was not new. As petitioner concedes (Pet. Br. 28 n.10; see also id. at 13), that doctrine actually predates Hale v. Henkel, supra. See J. Wigmore, Evidence Section 2264, at 3124 (1904). /19/ It was mentioned in passing in the Wilson case, 221 U.S. at 378, and it received explicit judicial acceptance in the 1920s. People v. Defore, 242 N.Y. 13, 27, 150 N.E. 585, 590 (1926) (Cardozo, J.); see also Haywood v. United States, 268 F. 795, 803 (7th Cir. 1920). In 1957, this Court recognized the doctrine in Curcio, 354 U.S. at 125. Justice Marshall discussed the act-of-production theory in his dissenting opinion in Couch v. United States, 409 U.S. 322, 346-347 (1973), just one Term before writing the opinion for the Court in Bellis, which once again reaffirmed the collective entity rule. See generally Alito, supra, 48 U. Pitt. L. Rev. at 65-66. Fisher put an end to the argument that a claim of privilege could be tied to the contents of the records; it left only the act of production as the basis for the privilege. Doe refined the ruling in Fisher that the act of production was the only basis on which an individual or sole proprietor could ground his Fifth Amendment claim. Neither case in any way expanded the act-of-production doctrine as a basis for asserting the privilege. That doctrine attained prominence after Fisher and Doe not because it was given more vitality, but because it was the only ground for resistance that was left. See generally Note, supra, 54 Fordham L. Rev. at 946-949. The elimination of the principal ground on which corporate custodians for six decades had unsuccessfully sought to defeat subpoenas for corporate documents did not suddenly promote the subsidiary act-of-production doctrine into a convincing rebuttal to the collective entity rule. /20/ This Court has for years recognized the coexistence of the act-of-production doctrine and the collective entity rule, and there is not, as petitioner contends (Pet. Br. 31-40), any logical inconsistency between the two doctrines. First, the act-of-production doctrine does not in any way undermine the agency theory on which the collective entity rule principally rests. If the individual producing corporate documents is not acting in his individual capacity, but only as an agent of the corporation, he cannot complain about being incriminated by the corporation's act of producing the documents any more than he can complain about being incriminated by the contents of the documents that the corporation discloses. Petitioner's attempt to refute this underlying rationale for the collective entity rule (Pet. Br. 37-39) rests in no part on Fisher and Doe but instead boils down to an assertion that this Court was simply wrong to employ this rationale in Wilson in 1911, Essgee in 1923, White in 1944, Curcio in 1957, and Bellis in 1974. We disagree with petitioner's assertion that this Court has repeatedly erred by differentiating a corporate agent's production of documents from the production of documents by an individual acting in a nonrepresentative capacity. Unless Hale v. Henkel is to be overturned and corporations are to be given Fifth Amendment privileges, it must be the case that some natural person can be compelled to act as the corporation's agent in order to fulfill the corporation's duty to produce documents. And, as we have shown, allowing the corporation rather than the government to select that person will frustrate legitimate government efforts to obtain documents and will predictably result in the nondisclosure of documents to which the government has every right. Petitioner apparently regards the "agency" rationale for the collective entity rule as a fiction that is both unjustified (Pet. Br. 38-39, 48) and without logical limit, as it could be used to compel even oral testimony before the grand jury (id. at 39). The answer to the latter point is that this Court's decision in Curcio places a logical limit on the use of the "agency" rationale: it may not be used as a basis for compulsion of oral testimony before the grand jury except, perhaps, when that oral testimony does nothing more than identify or authenticate previously produced documents (354 U.S. at 125); but it may be used as a basis for compulsion of the production of documents (id. at 123). Contrary to petitioner's claim (Pet. Br. 34-35), the Curcio case does not support his contention that there can be no logical distinction between the compulsion of incriminating oral testimony by a custodian of records, which is forbidden in some circumstances by Curcio, and the compulsion of tacitly communicative incriminating acts of production by a custodian of corporate records, which according to petitioner must also be forbidden. See also NACDL Br. 14. The argument that there is no such logical distinction is ironic, for two reasons. First, the whole point of Curcio is that there is a distinction between the oral testimony whose compulsion was attempted in that case and the tacit communications inherent in the act of producing documents. The government argued stenuously in Curcio that the collective entity rule recognized in White applied equally to compelled production of records and compelled oral testimony about "the whereabouts of books and records that have been subpoenaed but not producted" (354 U.S. at 123). The Court's response was to state emphatically that compelled production of records and the compelled oral testimony sought are not the same thing for purposes of the Fifth Amendment (id. at 123-124, 128). The very argument that petitioner now makes against the government is the argument that the Court rejected when it was advanced by the government. Second, the Court in Curcio was careful to limit its holding to forbid only testimony about the whereabouts of unproduced records and to leave open the question whether, as had been held in United States v. Austin-Bagley Corp., 31 F.2d 229 (2d Cir. 1929) (L. Hand, J.), "a corporate officer who has been required by subpoena to produce corporate documents may also be required, by oral testimony, to identify them" (354 U.S. at 125). Thus, contrary to petitioner's assertion (Pet. Br. 22), Curcio does not even stand for the proposition that compelled oral testimony by a corporate custodian identifying records is impermissible, much less the proposition that equivalent communications that are tacit in the act of producing records cannot be compelled. Petitioner's challenges to the other justifications that have historically been cited in support of the collective entity rule are also unpersuasive. The implied-waiver theory is no less valid now than it has been in the past. Although petitioner suggests that a waiver of the Fifth Amendment privilege must be knowing, intelligent, and voluntary, the Court has never required such an express waiver before applying the collective entity rule in the past, and petitioner gives no reason to require it now. In this area of the law, as in others, /21/ the necessity of government regulation may mean that one's voluntary choice to do business in a particular way -- without the need for any "knowing, voluntary, and intelligent" waiver -- leads to one's having less consitutional protection from government oversight than one would have enjoyed in another business or by doing business in a different way. /22/ Likewise, the practical considerations that have been cited in justification of the collective entity rule are at least as compelling now as they have been in the past. The law enforcement needs for access to corporate records are as great now as ever, and, as we have demonstrated, recognizing an act-of-production privilege for corporate representatives would seriously impair that interest. At the same time, the self-incrimination concerns that must be balanced against those law enforcement interests are much less compelling now than they were before Fisher and Doe, now that it has been recognized that there is no Fifth Amendment interest in shielding the contents of documents, but only a Fifth Amendment interest in preventing the much more limited disclosures inherent in the act of production. /23/ Because the collective entity rule is based on the fact that the corporate custodian is acting throughout in his representative rather than his individual capacity, a court may preclude the government from treating the custodian's conduct as his individual act for other purposes. Thus, because it is not the individual but the corporation that has turned over the documents, the government may not make evidentiary use of the fact that a particular individual within the corporation performed the physical act of production. That is not to say that the individual producing the documents may be given "constructive use immunity" for the act of production -- far from it. The government has every right to use the corporation's act of production to incriminate the individual, and any inferences drawn from the fact that the corporation produced the documents -- as opposed to inferences drawn from the fact that a particular individual produced the documents -- are fully available for the government's use. Use immunity protects a person who has incriminated himself against evidentiary or derivative use of the immunized communication by which he did so. By contrast, a prohibition against the government's treating the corporation's act of production as the individual's act would derive from the fact that the individual, as individual, is deemed to have performed no such act. /24/ Thus, the act of production by a corporate representative, if properly treated as the act of the corporation, may have testimonial value at a trial of the representative. It would authenticate the records and establish their existence and possession by the corporation -- evidence that could be used against the representative because it is the corporation's act and the unprivileged contents of the documents that incriminate him. The basis for the collective entity rule is not that the act of production is without testimonial value. In fact, the Fisher Court recognized the testimonial value of that act even while reaffirming the collective entity rule (425 U.S. at 411-412). The rule is instead based on the proposition that the testimony is the corporation's, not the representative's. Because the act of production is the corporation's, there is no reason it may not be used against the representative for whatever purpose the government chooses. The only thing the government may not do is to assert that the act of production was the personal testimonial act of the representative. /25/ In sum, the collective entity rule rests on a solid foundation, and we submit that the Court should reaffirm its holding that a corporate custodian is acting on behalf of the corporation, and not as an individual, when he produces corporate records. The individual's privilege against compelled self-incrimination can be fully protected by forbidding the government to treat the act of production as something that it is not: an individual act. The individual's desire not to have the corporation incriminate him is not protected, because the Fifth Amendment provides no such protection. B. Although this Court Should Not Reach Two Other Issues Discussed in Petitioner's Brief, Petitioner's Analysis of Those Issues Is Flawed Petitioner's brief discusses two issues that were not reached by either the district court or the court of appeals. Petitioner endeavors to show that the "facts and circumstances" of this case (Fisher, 425 U.S. at 410) support his claim that compelled production of corporate records would incriminate him (Pet. Br. 40-48). Petitioner also argues that, once he establishes that claim, only statutory use immunity and not the appointment of someone elso to produce the records will comport with the Fifth Amendment (id. at 46-47; see also NACDL Br. 21-30). We submit that neither issue is ripe for resolution by this Court. Our primary position, of course, is that these issues are not relevant to this case because, as the court of appeals held, the collective entity rule requires petitioner to comply with the subpoena without any further inquiry. If the Court rejects that argument and holds that there are some circumstances in which a custodian of corporate records may invoke his personal Fifth Amendment rights in response to a subpoena for those documents, we submit that the record is not adequate to permit the Court to determine whether petitioner may invoke the privilege in this case. According to Doe, the question whether "the act of producing records would involve testimonial self-incrimination" in a particular case rests on a "determination of factual issues" (465 U.S. at 613-614 (footnote omitted)). No such factual determination has yet been made in this case, because the government argued and both courts below agreed that any such factual determination was irrelevant to the task at hand. If this Court disagrees, then in our view both petitioner and the government would be entitled to make a new evidentiary presentation to the district court and to have that court resolve the issue, in the first instance, based on any findings of fact it might make. Indeed, petitioner concedes, at least in part, that "a remand for (a) limited purpose might be appropriate" (Pet. Br. 46 n.21). Only if petitioner succeeded in making a factual showing supporting a claim of act-of-production privilege would it become necessary to consider whether compelled production of the corporate records through some other person would be appropriate. Furthermore, resolution of that issue again might require factual findings. For example, despite the claimed status of Worldwide Purchasing and Worldwide Machinery as one-man operations, each corporation has two other officer-directors (petitioner's wife and mother) and one other employee (a secretary, also related to petitioner), and it might become necessary to determine whether there is any legal or factual obstacle to an attempt to require them to produce the corporate records. We therefore suggest that this Court not resolve these issues. If the Court is not disposed to affirm the judgment of the court of appeals on the grounds we have argued above, it should leave the remaining issues to the lower courts on remand for resolution in the first instance. We limit our discussion of these issues accordingly. Because petitioner has addressed these issues, however, we briefly mention what we perceive to be the major flaws in petitioner's analysis. 1. Petitioner's Claim that He Would Be Incriminated By the Act of Producing Corporate Documents Improperly Rests on the Contents of Those Documents As Fisher makes clear, there are two distinct ways in which the response to a document subpoena may communicate information to the government: the contents of voluntarily prepared records will communicate information (a fact that gives rise to no Fifth Amendment scrutiny), and the very act of production will sometimes communicate additional information. The sole object of Fifth Amendment protection is the additional information that is communicated by the act of production itself and not by the contents of the records. /26/ Petitioner initially appears to recognize this point. See Pet. Br. 41 (recognizing that privilege applies to "what the government will learn, not just from the contents of the records, but from Braswell's act of producing them"). But his effort to show that the act of production would incriminate him is not faithful to the distinction between the unprotected contents of the records and the protected communicative content of the act of production. In arguing that his tacit communication of the fact that the documents exist would incriminate him, petitioner rests on what the contents of those documents would show. See Pet. Br. 42 ("(d)ocuments are called for which may reflect taxable financial transactions"); id. at 43 ("(t)he records sought may reflect that items expensed on the corporate returns were in fact of a personal non-deductible nature"); id. at 45 (relying extensively on contents). /27/ In arguing that his tacit authentication of the documents would incriminate him, petitioner ignores the methods of authentication that are available to the government using the contents of the documents rather than the act of production. See, e.g., Fed. R. Evid. 901(b)(3) and (4); Fed. R. Evid. 901(b) advisory committee note; 5 D. Louisell & C. Mueller, Federal Evidence Section 515, at 78 (1981). /28/ Petitioner's analysis of the "possession and control" element of the Fisher test perhaps comes closer to recognizing the distinction between the unprotected contents of business records and the protected act of production. Yet, if it was a "foregone conclusion" in Fisher that possession and control would be established even without the act of production (425 U.S. at 411), surely that is just as true here. Petitioner, after all, cannot deny that any records of Worldwide Purchasing and Worldwide Machinery are in his possession and control: to the contrary, he emphasizes his "total control over the contents of the records of the business" and his "'abolute, total, complete'" authority over the corporation (Pet. Br. 5). Petitioner, indeed, admits in so many words that he is "the custodian of * * * records" of Worldwide Purchasing and Worldwide Machinery (id. at 7). /29/ This case is not at all like Doe, in which the court of appeals had postulated that "'the Government (was) unable to prove * * * that the appellee even is somehow connected to the business entities under investigation'" (465 U.S. at 613-614 n.12). Petitioner's connection to Worldwide Purchasing and Worldwide Machinery is a matter of public knowledge and is expressly conceded by petitioner. In sum, petitioner's analysis may tell us something about what the government will know following petitioner's response to the subpoena. But it tells us nothing about what that act of production -- as opposed to the unprotected contents of business records and foregone conclusions -- "adds * * * to the sum total of the Government's information" (Fisher, 425 U.S. at 411). 2. Petitioner's Claim that a Court May Not Require That Someone Else Be Designated to Produce the Corporate Documents Is Incorrect Abolition of the collective entity rule, which is what petitioner seeks in this case, makes no sense unless it can be done consistently with the undisputed principle that corporations have no Fifth Amendment privilege and must produce their documents in response to a subpoena, no matter who will be incriminated. That is why every court of appeals that has departed from the traditional rule has nevertheless held that, if a request is directed to the corporation and not to its custodian of records, the corporation must produce the records, appointing an agent from outside the corporation if necessary to do so (see note 13, supra). Petitioner (Pet. Br. 46-47) and amicus (NACDL Br. 21-30) criticize this result. They insist that, in cases where only the target of an investigation has access to or knowledge of some or all of the corporate records, the Fifth Amendment permits that person to maintain silence, even in response to the simple question -- asked by the corporation's own selected agent -- "Where are the corporate records, so that I may examine them and try to determine for myself which ones are responsive to the subpoena?" For 80 years, this Court has consistently maintained that every corporation, regardless of size, must turn over its documents in response to valid demands. Without a single exception that we know of, the lower courts still adhere to that rule, Petitioner purports to accept that rule. See Pet. Br. 34 ("(a) custodian claiming the privilege is not denying the Government's right to the records"). Yet, if petitioner prevails on this last argument, that will cease to be the law: there will be cases in which the government's only choices are granting use immunity to the target of the investigation or foregoing all access to a corporation's documents. The Constitution has never been held to require that result. It should not be so construed today. CONCLUSION The judgment of the court of appeals should be affirmed. Respectfully submitted. CHARLES FRIED Solicitor General WILLIAM F. WELD Assistant Attorney General WILLIAM C. BRYSON Deputy Solicitor General ROY T. ENGLERT, JR. Assistant to the Solicitor General JOEL M. GERSHOWITZ Attorney JANUARY 1988 /1/ The subpoena requested "all books, records, papers, and other data relating to Worldwide Machinery Sales, Inc., and Worldwide Purchasing, Inc., for the years 1982, 1983, 1984, and 1985, to include, but not limited to the following: (1) receipts and disbursements journals; (2) general ledger and subsidiaries; (3) accounts receivable/accounts payable ledgers, cards, and all customer data; (4) bank records of savings and checking accounts, including statements, checks, and deposit tickets; (5) contracts, invoices -- sales and purchase, conveyances, and correspondence; (6) minutes and stock books and ledgers; (7) loan disclosure statements and agreements; (8) liability ledgers; (9) retained copies of Forms 1120, W-2, W-4, 1099, 940 and 941." J.A. 21 n.1; see J.A. 6-7. /2/ Petitioner argued in the court of appeals (C.A. Br. 12, 19-21), and in his petition for a writ of certiorari (Pet. 16-17) that the collective entity rule does not apply to this case because Worldwide Purchasing and Worldwide Machinery are not collective entities. Indeed, that was petitioner's primary argument in the court of appeals; his brief declared that it was "fine with" him (C.A. Br. 19) to apply an analytic framework under which, "if the individual holds the records of a collective entity in a representative capacity, * * * no privilege will be recognized" (ibid.). Petitioner appears to have abandoned that argument in this Court, however. The portion of petitioner's brief that attempts to distinguish or to repudiate the collective entity rule (id. at 11-40) makes no mention of the argument that Worldwide Purchasing and Worldwide Machinery are not collective entities; petitioner is in fact emphatic that his argument applies to "(t)he Fifth Amendment rights of any records custodian, for any entity, albeit huge corporation, one-man corporation, or sole-proprietorship" (id. at 40; see also id. at 9; NACDL Br. 12-13 (argument applies to "custodian of documents of any organization -- regardless of size")). Therefore we, like petitioner and amicus, will focus our arguments on the question whether the collective entity rule applies to an attempt to invoke the Fifth Amendment on act-of-production grounds, and not on whether petitioner's corporations are otherwise exempt from the rule. /3/ In order for the collective entity rule to apply, it is sufficient (Bellis, 417 U.S. at 100) but not necessary (id. at 89) that the artificial entity in question be a corporation. Thus, the Court has held that the Fifth Amendment privilege may not be asserted as to the records of labor unions, United States v. White, 322 U.S. 694, 700 (1944); political parties, Rogers v. United States, 340 U.S. 367, 371-372 (1951); or business partnerships, Bellis v. United States, supra. /4/ See Wheeler, 226 U.S. at 489-490; Grant, 227 U.S. at 79-80; Essgee Co. v. United States, 262 U.S. 151, 155-158 (1923); United States v. White, 322 U.S. 694 (1944); Oklahoma Press Publishing Co. v. Walling, 327 U.S. 186, 205-206, 208, 210 (1946); Rogers v. United States, 340 U.S. 367, 371-372 (1951); Curcio v. United States, 354 U.S. 118, 122-125, 128 (1957); McPhaul v. United States, 364 U.S. 372, 380 (1960); George Campbell, 392 U.S. at 288-289; Bellis, 417 U.S. at 89-92; Fisher, 425 U.S. at 408, 411-412, 413 & n.14. Not all of those decisions were unanimous, but in each case the dissent either specifically endorsed the collective entity rule (see, e.g., McPhaul, 364 U.S. at 387; George Campbell, 392 U.S. at 290) or took issue with the majority on other grounds without discussing the validity of the collective entity rule. Justice McKenna dissented alone in the Wilson case, but he subsequently joined the Court's opinions in Wheeler, Grant, and Essgee, all of which reaffirmed the holding of Wilson. /5/ Justice Brennan and Justice Marshall, in separate opinions, took issue with the majority opinion in Fisher in several respects, but they explicitly agreed with the Court that a custodian of the records of a collective entity may not claim his privilege as a ground for refusing to produce the entity's records. 425 U.S. at 426, 430 n.9 (Brennan, J., concurring in the judgment); id. at 432 (Marshall, J., concurring in the judgment). /6/ Conyers, Corporate and White-Collar Crime: A View by the Chairman of the House Subcommittee on Crime, 17 Am. Crim. L. Rev. 287, 288 (1980). The annual cost of white-collar crime is estimated to be between $40 billion and $200 billion, in contrast to the annual cost of $4 billion attributable to crimes against property (id. at 288, 297). /7/ "Groups frequently are powerful and their illegal doings frequently are provable only by their records; and, since economic crimes (as contrasted with common law crimes) are usually not even discoverable without access to business records, a rule which privileged the production of such records whenever they incriminated the custodian would result in many (rather than few) of the violators going free." 8 J. Wigmore, Evidence Section 2259b, at 360-361 (J. McNaughton rev. ed. 1961). See generally Note, Fifth Amendment Privilege and Compelled Production of Corporate Papers After Fisher and Doe, 54 Fordham L. Rev. 935, 935-936 (1986). /8/ See Applegate, The Business Papers Rule: Personal Privacy and White Collar Crime, 16 Akron L. Rev. 189, 195-198 (1982); Vaira, Use of the Grand Jury to Obtain Business Records, 59 Chi. B. Rec. 32 (1977). /9/ Applegate, supra, 16 Akron L. Rev. at 198; Heidt, The Fifth Amendment Privilege and Documents -- Cutting Fisher's Tangled Line, 49 Mo. L. Rev. 439, 488 (1984). /10/ Amicus National Association of Criminal Defense Lawyers makes a different argument in an effort to show that abolition of the collective entity rule will not devastate the government's ability to detect and prosecute white-collar crime. Amicus contends that in only a "small number of cases" will use immunity be required as a prerequisite to compulsion of the custodian's production of the records (NACDL Br. 4), apparently because amicus believes that the custodian's claim of self-incrimination will fail on its merits in most cases. If that is so, then one must wonder why this issue has arisen in at least 17 published opinions of the courts of appeals just since 1984 (see Pet. Br. 31-32 n.11). The answer, of course, is that every corporate custodian with sufficient ingenuity can come up with a way to contend that the very act of producing records would somehow incriminate him, especially if it suffices to argue, as petitioner does, that "compliance with the subpoena would compel (the custodian) * * * to disclose the very existence of particular documents of which the Government is ignorant" (id. at 42). Every subpoena, except the hypothetical one that identifies each requested document with such specificity as to render it unique, potentially could compel the custodian to reveal the "existence of particular documents of which the Government is ignorant." /11/ As we explain in the next section, if the witness is a custodian of corporate documents, the government is entitled to that investigative lead under the collective entity rule, even though the particular individual whose knowledge is tacitly communicated by the production of the document may be incriminated by that tacit communication. Although the government cannot compel that individual to provide certain kinds of oral testimony (see Curcio v. United States, supra), the government is entitled to learn what the corporation knows (see United States v. Kordel, 397 U.S. 1, 8 (1970)), and the corporation -- through the individual acting on its behalf -- knows that the document fits within the categories described in the subpoena. /12/ Grants of act-of-production immunity would be especially problematic if, as one commentator has recently suggested, such immunity precludes the government from using the contents of the subpoenaed records against the individual who produced them under a grant of immunity. See Mosteller, supra, 73 Va. L. Rev. at 43; cf. In re Sealed Case, 791 F.2d 179 (D.C. Cir. 1986) (leaving question open), cert. denied, No. 86-312 (Oct. 20, 1986). Fortunately, this Court has already rejected that proposition. See Doe, 465 U.S. at 617 n.17. Indeed, petitioner concedes that the government, once it obtained corporate documents under a grant of act-of-production immunity, "'could then use the contents against any officer of the company, including the person to whom immunity was granted.'" Pet. Br. 35 (quoting Note, Organizational Papers and the Privilege Against Self-Incrimination, 99 Harv. L. Rev. 640, 649-650 (1986)). /13/ In re Sealed Case, 832 F.2d at 1278, 1282 & n.9; United States v. Antonio J. Sancetta, M.D., P.C., 788 F.2d 67, 74 (2d Cir. 1986) (one-person corporation); In re Two Grand Jury Subpoenae Duces Tecum, 769 F.2d 52, 57 (2d Cir. 1985) ("(t)here simply is no situation in which the Fifth Amendment would prevent a corporation from producing corporate records"); In re Special Federal Grand Jury Empanelled October 31, 1985, 819 F.2d 56, 57 n.1 (3d Cir. 1987); United States v. Rogers Transp., Inc., 793 F.2d 557, 558 (3d Cir. 1986) (one-person corporation); In re Grand Jury Matter (Brown), 768 F.2d 525, 529 & n.4 (3d Cir. 1985) (en banc); United States v. Lang, 792 F.2d 1235, 1240-1241 (4th Cir. 1986), cert. denied, No. 86-420 (Dec. 1, 1986); In re Grand Jury No. 86-3 (Will Roberts Corp.), 816 F.2d 569, 573 (11th Cir. 1987) (one-person corporation). There are the decisions on point of the five circuits that allow a corporate custodian, in at least some circumstances, to assert a personal act-of-production privilege in response to a subpoena for corporate documents. In the remaining circuits, the issue has never arisen because the courts have not departed from the traditional rule that the custodian may be compelled personally to produce the records of the collective entity. See J.A. 24-25 (collecting cases). /14/ See Wilson, 221 U.S. at 385 ("When the appellant became president of the corporation and as such held and used its books for the transaction of its business committed to his charge, he was at all times subject to its direction, and the books continuously remained under its control. If another took his place his custody would yield. He could assert no personal right to retain the corporate books against any demand of government which the corporation was bound to recognize."). Essgee, 262 U.S. 158 ("(A)n officer of a corporation in whose custody are its books and papers is given no right to object to the production of the corporate records because they may disclose his guilt. He does not hold them in his personal capacity and is not, therefore, protected against their production or against a writ requiring him as agent of the corporation to produce them."). /15/ See, e.g., Wheeler, 226 U.S. at 490 ("nor does the privilege of individuals against self-incrimination in the production of their own books and papers prevent the compulsory production of the books of a corporation with which they happen to be or have been associated"); White, 322 U.S. at 699 ("the official records and documents of (an) organization that are held by (individuals) in a representative rather than in a personal capacity cannot be the subject of the personal privilege against self-incrimination, even though production of the papers might tend to incriminate them personally"); Oklahoma Press, 327 U.S. at 208 ('the fair distillation (of prior cases), insofar as they apply merely to the production of corporate records and papers in response to a subpoena or order authorized by law and safeguarded by judicial sanction, seems to be that the Fifth Amendment affords no protection by virtue of the self-incrimination provision, whether for the corporation or for its officers"); Rogers, 340 U.S. at 371-372 (footnotes omitted) ("petitioner had no privilege with respect to the books of the Party, whether it be a corporation or an unincorporated association"); Curcio, 354 U.S. at 122 ("Nor may the custodian of corporate books or records withhold them on the ground that he personally might be incriminated by their production."); McPhaul, 364 U.S. at 380 (repeating above-quoted language from White); Bellis, 417 U.S. at 100 ("It is well settled that no privilege can be claimed by the custodian of corporate records, regardless of how small the corporation may be."); Fisher, 425 U.S. at 411-412 ("This Court has also time and again allowed subpoenas against the custodian of corporate documents * * * over claims that the documents will incriminate the custodian despite the fact that producing the documents tacitly admits their existence and their location in the hands of their possessor."); see also Wilson, 221 U.S. at 384 (custodian "could not withhold the books to protect himself from the effect of their disclosures"); Dreier, 221 U.S. at 400 ("By virtue of the fact that they were the documents of the corporation in his custody, * * * (Dreier) was under obligation to produce them when called for by proper process."); Essgee, 262 U.S. at 158 (custodian of corporate records "is not * * * protected against their production or against a writ requiring him as agent of the corporation to produce them"). /16/ The decisions on which we rely are in no way undercut by the fact that we now know that the Fifth Amendment claim as to "contents" should not have succeeded for the independent reason that the contents were voluntarily prepared (see Pet. Br. 38). The fact that the Court has now adopted a rule that would have provided an alternative justification for the results in those cases is no warrant for ignoring the quite different rule -- the collective entity rule -- that the Court announced as the basis for its holdings. /17/ Curcio, 354 U.S. at 122 ("Nor may the custodian of corporate books or records withhold them on the ground that he personally might be incriminated by their production."); ibid. ("the books and records of corporations cannot be insulated from reasonable demands of governmental authorities by a claim of personal privilege on the part of their custodian"); id. at 123-124 ("A custodian, by assuming the duties of his office, undertakes the obligation to produce the books of which he is custodian in response to a rightful exercise of the State's vistorial powers."); id. at 124-125 ("By accepting custodianship of records he 'has voluntarily assumed a duty which overrides his claim of privilege' * * * with respect to the production of the records themselves."); id. at 125 ("The custodian's act of producing books or records in response to a subpoena duces tecum is itself a representation that the documents produced are those demanded by the subpoena."); id. at 126 n.4 (quoting United States v. Austin-Bagley Corp., 31 F.2d 229, 233, 234 (2d Cir. 1929)) ("'That the production of the books and documents could be compelled, even if they contained entries incriminating the accused, is now well-settled law. * * * By accepting the office of custodian the holder not only exposes himself to producing the documents, but to making their use possible without requiring other proof than his own.'"); 354 U.S. at 128 ('"The compulsory production of corporate or association records by their custodian is readily justifiable, even though the custodian protests against it for personal reasons * * *."); Fisher, 425 U.S. at 408 ("despite Boyd (V. United States, 116 U.S. 616 (1886)), neither a partnership nor the individual partners are shielded from compelled production of partnership records on self-incrimination grounds"); id. at 411-412 ("This Court has also time and again allowed subpoenas against the custodians of corporate documents * * * over claims that the documents will incriminate the custodian despite the fact that producing the documents tacitly admits their existence and their location in the hands of their possessor."); id. at 413 (in prior cases, "the custodian of (a collective entity's) books * * * was ordered to respond to a subpoena * * * even though doing so involved a 'representation that the documents produced are those demanded by the subpoena'"); id. at 413 n.14 ("In these cases compliance with the subpoena is required even though the books have been kept by the person subpoenaed and his producing them would itself be sufficient authentication to permit their introduction against him."). /18/ It is therefore difficult to understand why the District of Columbia Circuit recently "f(ou)nd it significant that in Doe the Supreme Court * * * did not expressly limit its statement of the 'act-of-production' doctrine to individuals or sole proprietors, nor did it deny that custodians of collective entities could invoke the privilege on behalf of themselves" (In re Sealed Case, 832 F.2d at 1278 (emphasis added in part)). There having been no issue about collective entities before the Court in Doe, there was no reason for the Court to make express in Doe what it had already made express in Fisher (as well as Curcio) about the interrelationship of the act-of-production doctrine and the collective entity rule. /19/ In light of petitioner's claim that the Court's focus on the act of production in deciding document subpoena cases somehow undercuts the collective entity rule, it is particularly noteworthy that the Wigmore treatise, which gave birth to the act-of-production theory in 1904, also supports the collective entity rule. See 8 J. Wigmore, Evidence Section 2259b (J. McNaughton rev. ed. 1961). /20/ Reliance on the act-of-production doctrine recognized in Fisher and Doe as a basis for overturning the collective entity rule would be particularly curious, because the reason a corporate custodian resists a subpoena for corporate documents seldom has much to do with the incriminating aspect of the act of production. Instead, it is safe to say that the vast majority of all disputes in which the act-of-production doctrine is invoked are really attempts to avoid having to produce documents because of their incriminatory content (see Couch, 409 U.S. at 348 (Marshall, J., dissenting); Alito, supra, 48 U. Pitt. L. Rev. at 46, 48). Petitioner virtually concedes as much (Pet. Br. 41 & n.17). To overturn the collective entity rule through the device of the act-of-production doctrine would thus in effect revitalize, and greatly expand, the incriminating nature of the contents of documents as a basis for resisting subpoenas -- an odd result to attribute to two cases that purported to reject that ground for resisting subpoenas once and for all. In In re Grand Jury Matter (Brown), 768 F.2d 525 (3d Cir. 1985) (en banc), the court of appeals reached a contrary conclusion by reasoning that Fisher and Doe created new Fifth Amendment doctrine by "mak(ing) the significant factor, for the privilege against self-incrimination, * * * the communicative or noncommunicative nature of the arguably incriminating disclosures sought to be compelled" (768 F.2d at 528; accord In re Sealed Case, 832 F.2d at 1277). Petitioner endorses this reasoning explicitly (Pet. Br. 33) and similarly postulates that all pre-Fisher cases were decided "(b)efore (this Court's) adoption of a compelled testimony standard" (Pet. Br. 37). But it has always been necessary, in order to invoke the Fifth Amendment, to show that the arguably incriminating disclosure sought to be compelled is testimonial. It was fully recognized at the time of Wilson that the Fifth Amendment privilege applies only to testimonial communications (see, e.g., Holt v. United States, 218 U.S. 245 (1910)), and the contents of documents were at that time regarded as testimonial communications. The Court nonetheless saw fit to make an exception to the privilege for the contents of corporate documents, even when compelled production would incriminate the subpoenaed corporate representative himself. /21/ See, e.g., New York v. Burger, No. 86-80 (June 19, 1987) (junkyard owners may be subjected to searches that would violate the Fourth Amendment if they were engaged in other businesses); Shapiro v. United States, 335 U.S. 1 (1948) (entry into particular regulated industries subjects individuals and collective entities to requirements that they both keep and produce on demand "required records" whose compelled production might otherwise be inconsistent with the Fifth Amendment). /22/ Petitioner and amicus also rely on cases in which this Court has refused to find a valid waiver of Fifth Amendment rights even though individuals had engaged in the conduct in question with knowledge that a statute purported to require them to waive their rights. Pet. Br. 36-37; NACDL Br. 15-19. But none of those cases involved the very limited testimonial communications that are tacit in an act of producing corporate records, and none of those cases involved an attempt by an entity having no Fifth Amendment right to evade its duty to respond to valid process. Moreover, any assertion that petitioner was not on notice that incorporating his business constituted an implied waiver of the right to protect business documents from disclosure ignores decades of settled precedent from this Court. /23/ Petitioner's analysis of the justifications for the collective entity rule is correct in one limited respect: as he argues (Pet. Br. 39-40), the "privacy rationale" that this Court once advanced for the collective entity rule (see Bellis, 417 U.S. at 91-92) cannot survive Fisher and Doe. But, as petitioner concedes (Pet. Br. 34 n.12), Bellis did not rest on the privacy rationale alone but "reaffirm(ed) all of the Court's earlier justifications underlying the government's 'right' to business records." It is those traditional underlying justifications, and not just the erstwhile privacy rationale of Bellis, that petitioner must refute in order to prevail. He has not done so. /24/ We take the approach adopted by the Sixth and Eighth Circuits to be equivalent to the analysis that we suggest. The Sixth Circuit based its ruling on the fact that "(t)he custodian of corporate or partnership records acts only in a representative capacity, not as an individual, and production of the records is not a testimonial act of the custodian (but) * * * communicates nothing more than the fact that the one producing them is a representative of the corporation or partnership." In re Grand Jury Proceedings (Morganstern), 771 F.2d 143, 148, cert. denied, 474 U.S. 1033 (1985); see also In re Grand Jury Empanelled March 8, 1983, 722 F.2d 294, 297 (6th Cir. 1983), cert. dismissed, 465 U.S. 1085 (1984); In re Grand Jury Subpoena (85-W-71-5), 784 F.2d 857, 861 (8th Cir. 1986), cert. dismissed, No. 85-1987 (Jan. 15, 1987). /25/ Accordingly, although the Third Circuit reached the incorrect result in In re Grand Jury Matter (Brown), 768 F.2d 525 (1985) (en banc), the court may have been rightly disturbed by the government's suggestion that it could compel the witness in that case personally to produce the documents and then use his personal act of production against him, and by the government's refusal to accept delivery of the documents by the witness's attorney (768 F.2d at 526, 529 n.4). The proper result in Brown would have been for the court to compel production of the documents by Brown as the agent of the corporation, but to bar the government from making evidentiary use of the fact that it was Brown -- as opposed to simply the corporation -- that turned over the documents. Likewise, in In re Grand Jury Subpoenas Duces Tecum (Saxon Industries), 722 F.2d 981 (2d Cir. 1983), the court should not have remanded for the district court to decide whether to quash the subpoena on the ground that the former corporate officer's possession of the records could be used as evidence that he absconded with them. Rather, the court should have refused to quash the subpoena but, if the issue subsequently arose, the court should have prevented the government from making use of the fact that it was the former president, rather than someone else associated with the corporation, who produced the documents. /26/ It is erroneous to treat everything that the government knows after the act of production, but did not know before that act, as something that was communicated by the very act of production. Rather, the two distinct communications that have taken place -- communications by the unprotected contents of the documents themselves and communications by the act of production -- must be kept separate. A useful analytic aid to conducting this inquiry is to ask: What does the government know, given the act of production in response to a subpoena, that it would not have known if the documents had simply shown up, unsolicited, in the grand jury room? See Alito, supra, 48 U. Pitt. L. Rev. at 60-61. /27/ Petitioner relies (Pet. Br. 42 & n.19) on Professor Mosteller's article in this respect. But that article, like petitioner's own analysis, is flawed by its failure to treat the tacit communications inherent in the act of production as something to be measured at the margin -- rather than as a backdoor way to afford protection to the contents of the documents. That is also why Professor Mosteller reaches the conclusion, which is directly contrary to Doe, that act-of-production immunity protects the contents of documents. Compare Mosteller, supra, 73 Va. L. Rev. at 43, with Doe, 465 U.S. at 617 n.17. /28/ Petitioner also ignores the likelihood that his secretary could authenticate documents that she witnessed being written and documents that she received, typed, delivered, mailed, filed, read, or was otherwise familiar with (5 D. Louisell & C. Mueller, supra, Section 507, at 27). She could also authenticate the corporations' business ledgers and journals, assuming that she made entries, saw them being made, or is familiar with the corporations' recordkeeping procedures (4 id. Section 446, at 662-667 (1980); see also E. Cleary, McCormick on Evidence, Section 219, at 688 (3d ed. 1984)). To be sure, the government cannot in this case -- or in any other case -- show, before it sees the documents, that it is an absolute certainty that every corporate document can be authenticated by one of these means. But if inability to make that showing is fatal to the government's ability to obtain the documents by subpoena, then no subpoena will ever again be enforceable without a grant of use immunity. We do not think Fisher and Doe were designed to bring about that result. /29/ Although petitioner maintains elsewhere in his brief (Pet. Br. 10, 45) that he has never admitted that the subpoenaed documents exist or that he has possession and control of them, that is simply not so in light of petitioner's statement of the case in this Court. Indeed, petitioner has given the district court an inventory of the records responsive to the subpoena and an assurance that he will turn them over if his legal contentions do not prevail. See Pet. App. 12a; 11/26/86 Tr. 4-5, 9-11.