Citibank was asked to provide documents held in a foreign branch by a valid subpoena. Citibank complied with the subpoena in New York but refused to produce documents in Frankfurt, claiming it would expose them to civil liability under foreign law. The court had to decide if they had the power to require documents located in foreign jurisdictions, balancing the interests of different states, and if Citibank had a legally sufficient reason for disobedience.
United States v. First National City Bank (1968)
United States Court of Appeals for the Second Circuit
396 F.2d 897
Learn more about this case at https://www.lsd.law/briefs/view/united-states-v-first-national-city-bank-21188950
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