On September 16, 2025, Judge Trevor McFadden of the U.S. District Court for the District of Columbia dismissed Dr. Ralph de la Torre’s effort to bar criminal or civil enforcement of the Senate’s resolutions holding him in civil and criminal contempt of Congress.  In bringing his pre-enforcement challenge, Dr. de la Torre alleged that any effort to pursue civil or criminal sanctions in connection with the resolutions would entail further “punishment” for his having invoked his Fifth Amendment rights in refusing to testify before the Senate Health, Education, Labor, and Pensions (“HELP”) Committee regarding the bankruptcy of Steward Health Care.  Judge McFadden’s sweeping rejection of this challenge underscores the limited ability of congressional subpoena targets to seek relief in court and highlights the formidable protection the Constitution’s Speech or Debate Clause provides to congressional investigators.