Anthony S. Pitch v. United States

Three decades ago, we held that a federal court has inherent authority to order the disclosure of grand jury materials in situations not covered by the exceptions to secrecy set forth in Federal Rule of Criminal Procedure 6(e). See In re Petition to Inspect & Copy Grand Jury Materials (Hastings) , 735 F.2d 1261, 1268 (11th Cir. 1984) (setting out an "exceptional circumstances" standard). I would have decided Hastings differently because allowing the use of inherent authority to go beyond the exceptions to grand jury secrecy set forth in Rule 6(e) seems too open-ended to me. See Carlson v.…