Entergy Mississippi, Inc. v. State, 132 So. 3d 568

Entergy Mississippi serves Madison County and is the exclusive electric provider for two Madison County ZIPs; customers provide personal information for billing.
The Madison County Tax Assessor sought Entergy customer names/addresses to investigate homestead-exemption fraud by comparing to the tax roll.
Initial subpoenas sought two ZIP areas and directed production to the Tax Assessor’s Office; Entergy objected, insisting on a valid grand jury subpoena.
A second subpoena targeted additional ZIPs with production to the Tax Assessor’s Office; Entergy again objected as vague and overly broad.
A third subpoena for residential accounts in two ZIPs was issued to the grand jury; Entergy amended its motion to quash; circuit court denied the motion and a stay followed.
On appeal, the Mississippi Supreme Court applies de novo review and affirms the denial, concluding the subpoena could pertain to possible criminal tax violations and fall within grand jury authority.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the subpoena constitutes abuse of the grand jury process	Entergy asserts broad civil purpose and lack of individual suspicion.	County contends grand jury authority extends to civil matters aiding tax enforcement and potential criminal probes.	Subpoena not an abuse of the grand jury process.
Whether the tax assessor’s involvement improperly influenced the grand jury or violated secrecy/separation of powers	Entergy argues improper influence and power-sharing with the tax assessor.	County maintains broad information sources and prosecutor collaboration are permissible; no separation of powers violation.	Tax assessor involvement did not improperly influence or violate secrecy or separation of powers.
Whether the subpoena violates due process or customer privacy	Entergy argues customer names/addresses carry privacy rights.	County contends no reasonable expectation of privacy in names/addresses listed in public records; subpoena permissible.	Subpoena does not violate due process or customer privacy.
Whether the subpoena is an improper fishing expedition	Entergy claims lack of individualized suspicion renders the subpoena exploratory and improper.	County argues broad investigations are legitimate to ensure proper tax enforcement and potential criminality.	Subpoena is not an improper fishing expedition; it could aid a legitimate criminal investigation.

United States v. R. Enter., Inc., 498 U.S. 292 (U.S. 1991) (relevance standard for grand jury subpoenas: some relevance to investigation suffices)
Blair v. United States, 250 U.S. 273 (U.S. 1919) (grand jury power to investigate without case-specific charges)
United States v. Philadelphia & R.R. Co., 225 F.301 (E.D. Pa. 1915) (grand jury authority to determine whether a crime has been committed)
United States v. Morton Salt Co., 338 U.S. 632 (U.S. 1949) (grand jury may investigate on suspicion that law is violated without case specifics)
Calandra, 414 U.S. 338 (U.S. 1974) (grand jury sources of information are broadly drawn; appearance of outside witnesses not a secrecy violation)
Dionisio, 410 U.S. 1 (U.S. 1973) (grand jury need not require probable cause for subpoenas in advance)
McLendon v. State, 945 So.2d 372 (Miss. 2006) (roadblock analogy supporting broad state interest in enforcement)