Baltimore Dept. of Social Servs. v. Bouknight
In Baltimore Dept. of Social Servs. v. Bouknight, 493 U.S. 549, 107 L. Ed. 2d 992, 110 S. Ct. 900 (1990), the United States Supreme Court stated "where, by virtue of their character and the rules of law applicable to them, the books and papers are held subject to examination by the demanding authority, the custodian has no privilege to refuse production although their contents tend to criminate him." Bouknight, 493 U.S. at 558, 107 L. Ed. 2d at 1002 (quoting Wilson, 221 U.S. at 382, 55 L. Ed. at 780).