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On April 13, 2026, the NAM filed an amicus brief urging the Indiana Court of Appeals to reaffirm that Indiana law places meaningful limits on the power of executive branch officials to investigate private companies. In this case, the Indiana Attorney General launched an investigation into manufacturer Berry Global and several other Indiana businesses and nonprofits based on abstract forced labor and human trafficking concerns. His office issued a sweeping civil investigative demand to Berry, ordering the company to produce a wealth of confidential employee information. After Berry refused to turn over the information, the AG went to court to enforce the CID. The trial court ruled in Berry's favor, concluding that “there simply is not sufficient facts to infer reasonable cause exists to believe [Berry] has relevant information to an investigation for labor trafficking.” The instant appeal by the AG followed. Our amicus brief underscores the important role of Indiana courts to ensure that CIDs are lawful, proportionate, and tethered to a legitimate purpose. We further highlight the significant financial, operational and reputational burdens that companies are forced to shoulder in responding to CIDs.