Supreme Court upheld subpoenas of previous presidents' documents.

Quartz - This is not the first time a president’s records or testimony have been subpoenaed when he’s in office. In United States v. Nixon in 1974, Richard Nixon’s recordings were sought in a federal criminal investigation of his aides. In Clinton v. Jones in 1997, Bill Clinton was subpoenaed for a federal civil suit. In both of those cases, the high court ruled that presidents were not immune to these requests, prompting Nixon to quit the presidency and forcing Clinton to face suit.