The implications of recent decisions of the Supreme Court which have given new and expanded meanings to the procedural safeguards owing to a criminal defendant have not yet been fully realized. Most immediately, they will undoubtedly affect established practices of law enforcement agencies. An important consequence of these changes, however, may also be the extension of the right to counsel to the grand jury witness.
The Rights of a Witness Before a Grand Jury,
1967 Duke Law Journal
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