In Re Special Grand Jury 89-2

This is an appeal from a district court order releasing, for use in a civil case, transcripts of the grand jury testimony of potentially all witnesses who testified before the grand jury, based on a showing of need for the testimony of only three witnesses. 1 We reverse the district court’s decision, holding that: (1) a district court must evaluate the need for disclosure of grand jury testimony on a witness-by-witness basis; and (2) before releasing transcripts, the district court must • conduct an in camera review in order to limit the disclosure to the claimed need and make appropriate…