NASAA Series 63Remedies and Administrative ProvisionsMedium

During an investigation, the Administrator issues a subpoena to a witness requiring production of records. The witness refuses to comply without justification. What is the Administrator's proper recourse?

  1. AThe Administrator may petition the appropriate court to hold the witness in contempt
  2. BThe Administrator may impose an immediate criminal fine on the witness
  3. CThe Administrator must abandon the investigation, as subpoenas are not enforceable
  4. DThe Administrator may personally seize the records without further authorization
Show answer & explanation

Correct answer: A. The Administrator may petition the appropriate court to hold the witness in contempt

Administrators lack direct enforcement power over disobeyed subpoenas; they must apply to a court of competent jurisdiction, which can hold the noncompliant witness in contempt. This preserves judicial oversight of enforcement actions against individuals.

Why the other options are wrong

  • B. Administrators cannot impose criminal fines directly; only courts can do so.
  • C. Subpoenas are enforceable through the courts, so investigations need not be abandoned.
  • D. Administrators cannot self-execute seizures; judicial process is required.

Subpoena Enforcement

If a person refuses to comply with an Administrator's subpoena, the Administrator must seek court assistance, and the court may hold the person in contempt.

  • Administrators cannot enforce subpoenas unilaterally
  • Courts have contempt power over noncompliant witnesses
  • This process applies to both in-state and out-of-state witnesses

Memory trick: No badge without the judge — courts back the subpoena.

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