Volume 851 — Federal Reporter, Third Series

United States v. Rawls, No. 17-3205 (3d Cir. 2020) (formally, In re Grand Jury Subpoena Duces Tecum Dated March 25, 2015), is a precedential case decided by the United States Court of Appeals for the Third Circuit on February 6, 2020. The appeal addressed whether the 18-month limit on civil contempt confinement under 28 U.S.C. § 1826(a) applied to Francis Rawls, a former Philadelphia Police Department sergeant who had been incarcerated for over four years for refusing to comply with a court order to decrypt two encrypted external hard drives seized during a federal child pornography investigation. In a 2–1 decision, the Third Circuit ordered his release, holding that the statutory cap applied.