Not a problem under the rule of law: Congress can have the Justice Dept (the new one that takes its name seriously) serve Rove with a contempt citation for failing to obey the subpoena. U.S. marshals would then "escort" Rove before the committee. America could then watch Rove plead the 5th all day -- a fine way to seed deep public distrust and disgust for the neocon Republicans. To make the spectacle more effective, the committee could call Justice Dept officials as witnesses with Rove in the room to hear their "turncoat" testimony about his crimes. All on TV. Valuable grist for the historians' mills.
Mission accomplished!
All that's required is Democratic Congressional cojones. Under separation of powers, Obama has nothing to say about proceedings in the Legislative Branch and would be foolish to intervene.
The good news is that Conyers has said he will proceed with the investigation and if it had to go through a court, that was fine with him.
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