immunity is not affected by the fact that the witness appearance was pursuant to a court order. The immunity is not affected by the witness' domination of a corporate defendant already in action, or the witness' potential liability as a co-defendant. A witness who appears in court as part of his official duties is immune from service of civil process, and it is irrelevant that his appearance was not under subpoena. Contrary to the general rule, there has been opinion that non-resident witnesses are not exempt from civil process. Many courts encourage witnesses to come forward voluntarily and give testimony. Immunity is based on the theory that the court must be unimpeded in its goals, and fear of service could lead to witnesses not appearing, for fear of being served in another pending civil case. There are two general rules followed: The "sole purpose rule" where the rule cannot be invoked unless the only reason the party is in the jurisdiction is to attend the court's business. The "controlling reason doctrine", which is more liberal, and allows a person testifying more latitude. So called "long-arm statutes" have tended to mitigate immunity to some extent. Various "long-arm statutes" have changed the landscape of civil service across state lines. For instance, immunity from civil service to non-resident witnesses no longer applies in California after Silverman v. Superior Court 203 Cal. App. 3d 145 (Cal. Ct. App. 1988). Subpoena power defined in the Federal Administrative Procedure Act Following the United States Supreme Court ruling in Morgan v. United States, federal administrative law was ripe for significant reform. Administrative law had grown significantly during the Franklin Delano Roosevelt administration and the implementation of the numerous agencies promulgated under the New Deal. The decision in Morgan precipitated change in the federal system which had been deemed inadequate for the previous thirty five years. In 1941 the United States Attorney General's Committee presented its final report on federal administrative procedure. The report resulted in the Federal Administrative Procedure Act of 1946 (APA). A parallel report entitled the Benjamin Report was issued concerning administrative adjudication in the state of New York in 1942. The Federal Administrative Procedure Act of 1946 required hearings to have the qualities defined in §§ 553 and 554: For hearings involved in the taking of evidence, there shall preside: The agency One or more members of the body which comprises the agency; and