l protection doctrine but challenging current precedent). °4 Grand juries remain a fixture in the federal system and in roughly half the states. See Sara Sun Beale et al., Grand Jury Law and Practice § 1:5 (2d ed. 2017) (describing grand jury status and rules in states and noting states that have partially or wh

* * Professor of Law, S.J. Quinney College of Law of the University of Utah, Judge, U.S. District Court for the District of Utah, 2002-07. Thanks to Sara Sun Beale, Doug Beloof, Doug Berman, Russell Butler, Matt Cannon, Meg Garvin, Nancy King, Erik Luna, Peter McCabe, Benjamin McMurray, Ross McPhail, Dan Medwed,

riminal Law, 79 Minn. L. Rev. 455, 462-63 (1994) (attributing the federalization of crime to the expansion of the Commerce Clause under Perez). 6 Sara Sun Beale, What's Law Got To Do With It? The Political, Social, Psychological and Other Non-Legal Factors Influencing the Development of (Federal) Criminal La

riminal Law, 79 Minn. L. Rev. 455, 462-63 (1994) (attributing the federalization of crime to the expansion of the Commerce Clause under Perez). 6 Sara Sun Beale, What's Law Got To Do With It? The Political, Social, Psychological and Other Non-Legal Factors Influencing the Development of (Federal) Criminal La