Subject: Re: Default Judgment for Giuliani
Has any Federal Government official anywhere, ever been sanctioned like Giuliani for withholding documents?
Different procedural contexts.
In a civil suit, you have an obligation to provide access to responsive documents requested by the opposing party - subject to sanctions within the context of that suit if you don't comply. Any party to any civil lawsuit will face discovery sanctions if they don't comply with discovery orders. This is civil procedure 101 type stuff - discovery sanctions are imposed every single day against party litigants.
Congressional subpoenas are an entirely different ball of wax, because (unlike a civil court judge) Congress doesn't have direct enforcement powers. Moreover, unlike Congressional subpoenas of private individuals, Congressional subpoenas of federal government officials are inextricably linked to separation of powers issues, and are thus never going to result in either a quick judicial resolution or criminal sanctions.