This Note concludes that, in United States v. Williams, the Court placed too much emphasis on the historical independence of the grand jury. Such emphasis ignored recent changes in the grand jury system and the role the grand jury plays in protecting citizens from wrongful prosecution. This Note also suggests that the substantial exculpatory evidence rule better balances the interests promoted by the investigatory and protective functions of the grand jury. Finally, this Note concludes that the Court's expanded powers of review may unduly favor the government. The ultimate effect of this expansion will depend upon whether the Court grants review of similar cases in the future, and how it rules in each of those future cases. Even if the rule does not result in actual bias, however, it does display an undesirable appearance of unfairness. Footnotes