Ramon Saul Sanchez v. United States

Ramon Saul Sanchez appeals from the December 23, 1983, order of the District Court for the Southern District of New York (David N. Edelstein, Judge) refusing to terminate a commitment for civil contempt. Because Judge Edelstein’s brief explanation for his ruling creates uncertainty as to whether the standards enunciated in Simkin v. United States, 715 F.2d 34 (2d Cir.1983), have been properly applied, we remand the matter for further consideration.

Sanchez was subpoenaed before a grand jury in the Southern District investigating crimes allegedly committed by a Cuban exile group known as “Omega…