They have police power, so they could arrest him; it has happened 6-7 times in the past. But most likely he will go before a judge and be forced to cough up all the documents. If there is evidence of a coverup in them, he will do time. If not, he can still lose his law license for lying to Congress, and there still is another issue on the table besides Fast and Furious. He should retire; he's an albatross on Obama's neck.