In December 2019, Livingston partially dissented from a federal appeals court ruling ordering that Donald Trump comply with a subpoena and turn over his tax returns to the U.S. House of Representatives.
Livingston partly dissented from an order in December 2019 by a federal appeals court that mandated Donald Trump's compliance with a subpoena for his tax returns, which he was required to turn over to the U.S. House of Representatives.