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Justia Daily Opinion Summaries

US Court of Appeals for the Eleventh Circuit
March 28, 2020

Table of Contents

Pitch v. United States

Criminal Law

Williamson v. Travelport, LP

ERISA

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US Court of Appeals for the Eleventh Circuit Opinions

Pitch v. United States

Docket: 17-15016

Opinion Date: March 27, 2020

Judge: Tjoflat

Areas of Law: Criminal Law

Plaintiff petitioned the district court for the grand jury transcripts related to the Ford Lynching—a horrific event involving the murders of two African American couples for which no one has ever been charged—to be used in his book about the lynching. The district court granted the petition, finding that the historical significance of the grand jury's investigation, and the critical role the records of that investigation would play in enhancing the historical record on this tragic event, amounted to "exceptional circumstances" that justified the use of the court's inherent power to order disclosure. A panel of the Eleventh Circuit affirmed. After rehearing en banc, the en banc court held that Rule 6 of the Federal Rules of Criminal Procedure is exhaustive, and that district courts do not possess inherent, supervisory power to authorize the disclosure of grand jury records outside of Rule 6(e)(3)'s enumerated exceptions. Therefore, the en banc court overruled In re Petition to Inspect & Copy Grand Jury Materials (Hastings), 735 F.2d 1261 (11th Cir. 1984), which held to the contrary. The en banc court reversed the district court's judgment.

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Williamson v. Travelport, LP

Docket: 18-10449

Opinion Date: March 27, 2020

Judge: Jordan

Areas of Law: ERISA

Plaintiff filed a class action against Travelport and the Galileo & Worldspan U.S. Legacy Pension Plan under the Employee Retirement Income Security Act of 1974, alleging claims for improperly withheld pension benefits, document-disclosure penalties, and breach of fiduciary duties. The district court dismissed all claims. With respect to plaintiff's claim for benefits, the Eleventh Circuit reversed and remanded for the district court to review her claim anew after Travelport has certified and submitted the complete and accurate administrative record. The court reversed the district court's award of attorney's fees, but otherwise affirmed the district court's judgment.

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