In the Second Circuit's Trump v. Vance (2019) opinion, Judge Katzmann, writing for a unanimous three judge panel, held that the president is not immune from the enforcement of a state grand jury subpoena directing a third party to produce non-privileged material, even when the subject matter under investigation pertains to the President and that a state grand jury may permissibly issue subpoenas in aid of its investigation of potential crimes committed by persons within its jurisdiction, even if that investigation may in some way implicate the President. In June 2020, the Supreme Court affirmed that ruling in Trump v. Vance.