People v. Di Napoli

In People v. Di Napoli (27 N.Y.2d 229 [1970]) the Court of Appeals examined the five most frequently mentioned reasons for maintaining grand jury secrecy and found none sufficient to prevent disclosure of grand jury evidence to the Public Service Commission to aid the agency in its investigation of rates charged by an electric utility under its supervision. Importantly, in explaining its holding, the court took pains to point out that its ruling "will not sanction any general disclosure or widespread publication of the minutes" (27 N.Y.2d at 237), and involved "a proceeding long concluded." (Id. at 233.)