A federal judge abused his discretion by sanctioning an assistant federal public defender over subpoena procedures, the U.S. Court of Appeals for the Sixth Circuit has ruled.

The court vacated Northern District of Ohio Judge John Adams’ September 2011 order detailing federal defender Debra Migdal’s actions that he deemed sanctionable. The panel also reversed Adams’ May 2012 public reprimand of Migdal and dismissed the sanctions proceedings.