Which U.S. Supreme Court case held that the President is not immune from criminal subpoenas?

United States v. Nixon held that the President was not absolutely immune from a criminal subpoena seeking evidence in a pending prosecution.

The case grew out of the Watergate investigation. Special Prosecutor Leon Jaworski subpoenaed tape recordings and documents from President Richard Nixon for use in the criminal trial of former White House aides. Nixon argued that executive privilege allowed him to withhold the materials, but the Supreme Court unanimously rejected an absolute privilege based only on a generalized need for confidentiality.

Chief Justice Warren Burger’s opinion recognized that presidential communications can receive a presumptive degree of protection, especially when genuine military or diplomatic secrets are involved. However, that interest had to yield to the specific need for evidence in a criminal trial and to the demands of due process. The Court ordered Nixon to comply with the subpoena.

A frequent confusion is with Clinton v. Jones, which concerned a civil lawsuit against a sitting president, not a criminal subpoena for presidential recordings. Youngstown Sheet & Tube v. Sawyer involved presidential power over domestic industry, while Marbury v. Madison established judicial review.