`United States Court of Appeals
`Tenth Circuit
`December 18, 2015
`Elisabeth A. Shumaker
`UNITED STATES COURT OF APPEALS
`Clerk of Court
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`PUBLISH
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`TENTH CIRCUIT
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`NEIL FEINBERG; ANDREA E.
`FEINBERG; KELLIE MCDONALD,
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`Petitioners,
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`v.
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`COMMISSIONER OF INTERNAL
`REVENUE,
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`Respondent.
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`No. 15-1333
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`Petition for Writ of Mandamus to the
`United States Tax Court
`(T.C. Nos. 10083-13, 10084-13)
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`James D. Thorburn of The Law Office of James D. Thorburn, LLC, Greenwood
`Village, CO (Richard A. Walker of The Law Office of Richard A. Walker, P.C.,
`Longmont, CO, with him on the petition) for Petitioners.
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`Patrick J. Urda, Attorney, Appellate Section, Tax Division (Caroline D. Ciraolo,
`Acting Assistant Attorney General, Tax Division, and Gilbert S. Rothenberg and
`Richard Farber, Attorneys, Appellate Section, Tax Division, with him on the
`response) of the United States Department of Justice, Washington, D.C., for
`Respondent.
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`Before GORSUCH, HOLMES, and MORITZ, Circuit Judges.
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`GORSUCH, Circuit Judge.
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`This case owes its genesis to the mixed messages the federal government is
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`sending these days about the distribution of marijuana. The Feinbergs and Ms.
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`McDonald run Total Health Concepts, or THC, a not-so-subtly-named Colorado
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`marijuana dispensary. They run the business with the blessing of state authorities
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`but in defiance of federal criminal law. See 21 U.S.C. § 841. Even so, officials
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`at the Department of Justice have now twice instructed field prosecutors that they
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`should generally decline to enforce Congress’s statutory command when states
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`like Colorado license operations like THC. At the same time and just across 10th
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`Street in Washington, D.C., officials at the IRS refuse to recognize business
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`expense deductions claimed by companies like THC on the ground that their
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`conduct violates federal criminal drug laws. See 26 U.S.C. § 280E. So it is that
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`today prosecutors will almost always overlook federal marijuana distribution
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`crimes in Colorado but the tax man never will.
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`Our petitioners are busy fighting the IRS’s policy. After the agency
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`disallowed their business expense deductions and sent them a large bill, the
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`Feinbergs and Ms. McDonald challenged that ruling in tax court. Among other
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`things, they argued that the agency lacked authority to determine whether THC
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`trafficked in an unlawful substance and, as a result, they suggested that their
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`deductions should have been allowed like those of any other business. As the
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`litigation progressed, though, the IRS issued discovery requests asking the
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`petitioners about the nature of their business — no doubt seeking proof that they
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`are indeed trafficking in marijuana, just as the agency alleged. The Feinbergs and
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`Ms. McDonald resisted these requests, asserting that their Fifth Amendment
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`privilege against self-incrimination relieved them of the duty to respond.
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`It’s here where the parties’ fight took an especially curious turn. The IRS
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`responded to the petitioners’ invocation of the Fifth Amendment by filing with
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`the tax court a motion to compel production of the discovery it sought. Why the
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`agency bothered isn’t exactly clear. In tax court, after all, it’s the petitioners who
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`carry the burden of showing the IRS erred in denying their deductions — and by
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`invoking the privilege and refusing to produce the materials that might support
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`their deductions the petitioners no doubt made their task just that much harder.
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`See Tax Ct. R. 142(a)(1). And harder still because in civil matters an invocation
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`of the Fifth Amendment may sometimes lawfully result in an inference that what
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`you refuse to produce isn’t favorable to your cause. See, e.g., Baxter v.
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`Palmigiano, 425 U.S. 308, 318 (1976).
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`Still, the IRS chose to pursue a motion to compel. And in support of its
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`motion the agency advanced this line of reasoning. Yes, of course, the IRS said,
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`it thinks THC’s deductions are impermissible precisely because they arise from
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`activity proscribed by federal criminal statutes. Yes, the Fifth Amendment
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`normally shields individuals from having to admit to criminal activity. But, the
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`IRS argued, because DOJ’s memoranda generally instruct federal prosecutors not
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`to prosecute cases like this one the petitioners should be forced to divulge the
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`requested information anyway. So it is the government simultaneously urged the
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`court to take seriously its claim that the petitioners are violating federal criminal
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`law and to discount the possibility that it would enforce federal criminal law.
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`Ultimately, the tax court sided with the IRS and ordered the petitioners to
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`produce the discovery the agency demanded — and it is this ruling the Feinbergs
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`and Ms. McDonald now ask us to overturn. Because the tax court proceedings are
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`still ongoing and no final order exists that might afford this court jurisdiction in
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`the normal course, the petitioners seek a writ of mandamus. But, of course,
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`courts of appeals only rarely intervene in ongoing trial court proceedings, and
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`winning a writ of mandamus poses a special challenge. To secure a writ, the
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`petitioners must show that no other adequate means exist to secure the relief they
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`seek. They must also show a clear and indisputable entitlement to that relief.
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`And even if they can satisfy these two requirements, the petitioners still must
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`convince this court that exercising its discretion to intervene in an ongoing trial
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`court proceeding is “appropriate” in the interests of justice. See Cheney v. U.S.
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`Dist. Court, 542 U.S. 367, 380-81 (2004); Kerr v. U.S. Dist. Court, 426 U.S. 394,
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`403 (1976); United States v. Copar Pumice Co., 714 F.3d 1197, 1210 (10th Cir.
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`2013).1
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`1 At times our cases have suggested that, when a petitioner seeks a writ of
`mandamus to vindicate a claim of privilege in response to an adverse discovery
`ruling, this court will apply a two-prong test before considering the merits of the
`petition — asking first whether “(1) disclosure of the allegedly privileged or
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`When it comes to establishing a clear and indisputable entitlement to relief,
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`you might wonder if the petitioners are indeed able to bear the burden the law
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`imposes on them. Of course it’s true, as the IRS argues, that to invoke the Fifth
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`Amendment you must “face some authentic danger of self-incrimination.” United
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`States v. Rivas-Macias, 537 F.3d 1271, 1277 (10th Cir. 2008) (internal quotation
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`marks omitted). And it’s true, as the IRS stresses, that two consecutive Deputy
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`Attorneys General have issued memoranda encouraging federal prosecutors to
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`decline prosecutions of state-regulated marijuana dispensaries in most
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`circumstances.2 But in our constitutional order it’s Congress that passes the laws,
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`Congress that saw fit to enact 21 U.S.C. § 841, and Congress that in § 841 made
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`the distribution of marijuana a federal crime. And, frankly, it’s not clear whether
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`informal agency memoranda guiding the exercise of prosecutorial discretion by
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`field prosecutors may lawfully go quite so far in displacing Congress’s policy
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`directives as these memoranda seek to do. There’s always the possibility, too,
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`confidential information renders impossible any meaningful appellate review of
`the claim of privilege or confidentiality; and (2) the disclosure involves questions
`of substantial importance to the administration of justice.” Barclaysamerican
`Corp. v. Kane, 746 F.2d 653, 654-55 (10th Cir. 1984) (internal quotation marks
`omitted). The parties before us debate whether this test merely restates the
`traditional test for mandamus relief we’ve outlined in the text or whether it
`imposes a more onerous burden on the petitioner. Who’s right, though, proves
`immaterial in light of our assessment that petitioners in this case fail even under
`the traditional mandamus standard.
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`2 See Memorandum from David W. Ogden, Deputy Att’y Gen., U.S. Dep’t
`of Justice to Selected U.S. Att’ys (Oct. 19, 2009), revised by Memorandum from
`James M. Cole, Deputy Att’y Gen., U.S. Dep’t of Justice (Aug. 29, 2013).
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`that the next (or even the current) Deputy Attorney General could displace these
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`memoranda at anytime — by way of illustration look no further than DOJ’s (still)
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`evolving views on corporate waivers of the attorney-client privilege expressed in
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`so many memoranda by so many Deputy Attorneys General over so many years.3
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`In light of questions and possibilities like these, you might be forgiven for
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`wondering whether, memos or no memos, any admission by the petitioners about
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`their involvement in the marijuana trade still involves an “authentic danger of
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`self-incrimination.” Maybe especially given the fact that the government’s
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`defense in this case is wholly premised on the claim that the petitioners are, in
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`fact, violating federal criminal law. And given the fact that counsel for the
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`government in this appeal candidly acknowledged that neither the existence nor
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`the language of the DOJ memoranda can assure the petitioners that they are now,
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`or will continue to be, safe from prosecution. And given the fact that this court
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`has long explained that, once a witness establishes that “the answers requested
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`would tend to incriminate [him]” under the law of the land, the Fifth Amendment
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`may be properly invoked without regard to anyone’s “speculat[ion] [about]
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`3 See Memorandum from Eric H. Holder, Jr., Deputy Att’y Gen., U.S.
`Dep’t of Justice to All Component Heads & U.S. Att’ys (June 16, 1999), revised
`by Memorandum from Larry D. Thompson, Deputy Att’y Gen., U.S. Dep’t of
`Justice (Jan. 20, 2003), revised by Memorandum from Robert D. McCallum, Jr.,
`Acting Deputy Att’y Gen., U.S. Dep’t of Justice (Oct. 21, 2005), revised by
`Memorandum from Paul J. McNulty, Deputy Att’y Gen., U.S. Dep’t of Justice
`(Dec. 12, 2006), revised by Memorandum from Mark Filip, Deputy Att’y Gen.,
`U.S. Dep’t of Justice (Aug. 28, 2008), revised by Memorandum from Sally Q.
`Yates, Deputy Att’y Gen., U.S. Dep’t of Justice (Sept. 9, 2015).
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`whether the witness will in fact be prosecuted.” United States v. Jones, 703 F.2d
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`473, 478 (10th Cir. 1983).
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`But even if their Fifth Amendment objection bears merit, the petitioners
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`still face a problem. As we’ve seen, a writ of mandamus isn’t available when an
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`appeal in the normal course would suffice to supply any necessary remedy. And
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`in Mid-America’s Process Service v. Ellison, 767 F.2d 684 (10th Cir. 1985), this
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`court expressly held that any error in a district court’s order compelling
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`production of civil discovery that the petitioners believed protected by the Fifth
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`Amendment could be satisfactorily redressed in an appeal after final judgment.
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`Id. at 685-86. A holding that would seem to cover the very situation we now
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`face.
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`Admittedly, the government unearthed Mid-America’s Process only after
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`briefing in this appeal finished, citing the case for the first time in a supplemental
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`letter to the court. But the petitioners have now had a chance to consider and
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`reply to the government’s submission concerning Mid-America’s Process. And,
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`in our judgment, they have identified no satisfactory way to distinguish the
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`decision. The petitioners do argue that their case involves the Fifth Amendment
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`rights of natural persons, while Mid-America’s Process involved a corporation’s
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`claim to a Fifth Amendment privilege against self-incrimination. And, they note,
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`the Supreme Court has cast doubt on the viability of corporate invocations of the
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`privilege. See Braswell v. United States, 487 U.S. 99, 116 (1988). But while not
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`without some surface appeal, we don’t see how on more careful examination this
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`distinction will do. For Mid-America’s Process expressly looked past the
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`corporate form of the claimant in that case, took account of the individual
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`petitioners’ underlying privilege claims, and held that an appeal after final
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`judgment would suffice to remedy any individual injury as well. See 767 F.2d at
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`685-86 & n.1.4
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`Besides, even if Mid-America’s Process didn’t control this case (it does)
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`the petitioners still offer us no persuasive reason for thinking an appeal after final
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`judgment would fail to remedy any wrong they might suffer. Suppose the
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`petitioners are right and the tax court’s order compelling production violates their
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`Fifth Amendment rights. If they defy the tax court’s order and that court issues
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`an improper monetary or other sanction, this court would seem well able to undo
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`the sanction after final judgment. By contrast, if the petitioners choose to comply
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`with the discovery order under protest and the materials they produce are
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`unlawfully used against them at trial, this court would still seem to enjoy ample
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`4 Despite the government’s urging, we do not think the disposition of this
`appeal is controlled by Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100
`(2009). Mohawk involved not a mandamus petition raising the Fifth Amendment
`privilege but an argument that a discovery order infringing upon the attorney-
`client privilege was an immediately appealable collateral order under the Cohen
`doctrine. Id. at 103. What’s more, in dismissing the appeal, the Court in Mohawk
`relied on the fact that the appellant had at least three remaining options for
`challenging the discovery order: interlocutory appeal, writ of mandamus, or post-
`judgment appeal. Id. at 110-11. In contrast and given that the tax court denied
`the petitioners leave to file an interlocutory appeal, an adverse decision as to this
`petition would leave the petitioners with none but the final option.
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`authority to offer a remedy, maybe even in the form of a new trial without resort
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`to the materials in question.
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`Of course there are nuances here, but even they seem like they can be fairly
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`addressed later. For example, if the petitioners stand on their privilege we would
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`face the difficulty of separating out a permissible adverse inference (sometimes
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`employable, as we’ve seen, in civil cases even when the Fifth Amendment is
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`validly invoked) from an impermissible sanction. But no one suggests that task is
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`beyond us after final judgment. Similarly, if the petitioners choose to produce the
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`discovery under compulsion we might have to confront the question whether any
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`error by the tax court in ordering production was harmless and so beyond our
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`power to remedy after final judgment. But that sort of inquiry seems built into
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`the mandamus standard too. See, e.g., Petersen v. Douglas Cty. Bank & Trust
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`Co., 940 F.2d 1389, 1392 (10th Cir. 1991). Neither is it clear that an erroneous
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`order compelling production in this civil case would yield an unremediable
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`negative impact for the petitioners in a later criminal proceeding. For should they
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`elect, under threat of sanction, to comply with the tax court’s order — and should
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`it turn out that order was entered in error — the petitioners might later move to
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`suppress any of the evidence they produced on the ground that the production was
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`made involuntarily — a point even the government in this appeal does not
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`dispute. See, e.g., Minnesota v. Murphy, 465 U.S. 420, 425, 434 (1984);
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`Lefkowitz v. Cunningham, 431 U.S. 801, 805 (1977).
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`In the end, then, the petitioners fail to offer a convincing reason to think
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`that without an immediate remedy they will face an irreparable injury. Maybe
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`we’re missing something. Maybe a future party will show us what it is we’re
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`missing. But the petitioners have not done that much here. And that by itself
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`supplies an independent reason, beyond even our controlling precedent, to
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`withhold the extraordinary remedy of mandamus in this case.
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`The petition is denied.
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