The Court of Appeals for the First Circuit has held, at least implicitly, that a grand jury subpoena seeking hair samples need not be supported by either a warrant or probable cause. In re De Jesus Berrios, 706 F.2d 355 (1st Cir.1983). Other circuit courts of appeals agree. See, e.g., In re Grand Jury Proceedings (Mills), 686 F.2d 135, 139 (3rd Cir.1982) (“[W]e conclude that there is no greater expectation of privacy with respect to hair which is on public display than with respect to voice, handwriting or fingerprints. ... If fingerprints can be subjected to compelled disclosure by the grand jury without implicating the Fourth Amendment, it follows logically that the hair strands can as well.”); In re Grand Jury Proceedings Involving Eve Rosahn, 671 F.2d 690, 695 (2d Cir.1982) (<HOLDING>). Thus, it follows that the grand jury’s
holding that a grand jurys subpoena of fingerprints handwriting exemplars and hair samples need not be supported by a search warrant or a showing of reasonableness holding that while a grand jury subpoena for the production of books and papers may implicate the fourth amendment when presented with a challenge to such a subpoena a court need only determine whether the request is far too sweeping in its terms to be regarded as reasonable holding that a grand jury subpoena seeking a voice exemplar did not implicate fourth amendment rights but suggesting that even if it had at most the government would have been required to demonstrate that the grand jury subpoena was reasonable holding that a denial of a motion to quash a grand jury subpoena is not final and therefore not appealable holding that because a grand jury subpoena issued through normal channels is presumed to be reasonable  the burden of showing unreasonableness must be on the subpoena recipient who seeks to avoid compliance but recognizing that a court may be justified under some circumstances in requiring the government to reveal the general subject of the grand jurys investigation before requiring the challenging party to carry its burden of persuasion