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The point that many others are missing here, is that Congress' power to investigate is an Article One constitutional privilege, as also is the power of impeachment. Congress does not need due process or probable cause to investigate, as their constitutional processes are unrestrained. This is similar to the President's pardon power being unrestrained.How would you propose a court determine if a legislative purpose was legitimate?
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All that matters is,
"Does Congress have legitimate domain over the specific item(s) or person in question?"
The above (in italics), is currently what the courts are deciding in each subpoena case. The courts are not deciding due process or probable cause. This is a different legal realm, than things like due process or probably cause.