With no explanation, chose the best option from "A", "B", "C" or "D". the likelihood to deprive a defendant of due process of law. Courts have inherent power to protect a defendant’s rights from being violated in a criminal proceeding. Miranda v. Arizona, 384 U.S. 436, 478-79, 86 S.Ct. 1602, 1630, 16 L.Ed.2d 694, 726 (1966) (requiring the police to inform a person in custody before the police can begin an interrogation of the person’s constitutional right against self-incrimination, the right to have an attorney present at the interrogation, and the right to have an attorney appointed for them if the person cannot afford one); State v. Lawrence, 167 N.W.2d 912, 914 (Iowa 1969) (stating the court has inherent power to limit attendance at a trial “to reasonably protect the rights of parties and witnesses”); State v. Eads, 166 N.W.2d 766, 768-69 (Iowa 1969) (<HOLDING>); Hall v. Washington County, 2 Greene 473,

A: holding that due process rights were not violated by the district court failing to expressly articulate that it was imposing sanctions pursuant to its inherent power
B: recognizing courts inherent power to issue subpoenas
C: recognizing inherent power of courts of appeals
D: holding courts have inherent power to compel discovery of the states evidence to protect a defendants due process rights
D.