2nd Circuit Rejects Act of State and Immunity Defenses in Contempt Ruling Against Marcoses for Noncompliance with Subpoena

Ferinand and Imelda Marcos were indicted by a grand jury in Manhattan on October 21, 1988 for racketeering and other offenses relating to obtaining money and investing in the U.S., during and after their leadership positions in the Philippines.  On October 19, 1988, the Second Circuit Court of Appeals affirmed orders of the district court, finding them in civil contempt for their failure to comply with four grand jury subpoenas.