THE INVESTIGATION OF CHURCHES APPEARS TO RAISE THESE TACIT ASSUMPTIONS: (1) THAT STATE INTERVENTION IS MOST LIKELY TO OCCUR SUCCESSFULLY WHERE THE CHURCH IS NOT AN 'ACKNOWLEDGED' COMMONLY KNOWN INSTITUTION; (2) THAT GOVERNMENT INTERVENTION IS MORE LIKELY, IN PROPORTION TO THE GENERAL UNWILLINGNESS OF THE SOCIETY, TO TOLERATE SOME OF THE MORE EXTREME PRACTICES, SUCH AS SNAKE WORSHIP OR FRAUD; AND (3) THAT THE COURTS WILL NOT PERMIT QUESTIONING OF THE CONTENT OR VALIDITY OF AN INDIVIDUAL'S RELIGIOUS BELIEFS OR THE SINCERITY OF SUCH BELIEFS BUT WHENEVER BOOKS OR RECORDS OF CHURCHES ARE SUBPOENAED OR CHURCH MEMBERS ARE SUBPOENAED, WOULD PERMIT WIDE LATITUDE IN QUESTIONING. IN EVERY INVESTIGATION OF A CHURCH, THE GOVERNMENT WILL HAVE THE ONUS OF SHOWING THAT THE SUBJECT MATTER OF THE INVESTIGATION IS IMMEDIATE, SUBSTANTIAL, AND SUBORDINATING; THAT THERE IS A SUBSTANTIAL CONNECTION BETWEEN THE INFORMATION SOUGHT FROM THE WITNESSES AND THE GOVERNMENTAL INTEREST IN THE SUBJECT MATTER OF THE INVESTIGATION; THAT THE INTEREST OF THE GOVERNMENT IS OVERRIDING; AND THAT THE MEANS FOR OBTAINING THE INFORMATION IS NOT MORE DRASTIC THAN NECESSARY TO SATISFY THE ASSERTED INTEREST OF THE GOVERNMENT. THE SHOWING WILL USUALLY BE IN CAMERA. DEFENSE COUNSEL, BEFORE PROCEEDING WITH THEIR CLAIM OF PRIVILEGES, ON A MOTION TO QUASH A SUBPOENA, MAY CLARIFY THE RECORD IN OPEN COURT BY OBJECTING TO THE SECRECY OF THE PROCEEDINGS. IN ADDITION, COUNSEL MAY OBJECT TO TESTIMONIAL INFORMANTS WHO MAY THEMSELVES HAVE BEEN IN VIOLATION OF FIRST AMENDMENT PRIVILEGES. VARIOUS TECHNICAL ISSUES ARE DISCUSSED IN DETAIL. FOR RELATED ARTICLES, SEE NCJ 62048.