In United States v. Under Seal, 737 F.3d 330 (4th Cir. 12/13/13), here, the Fourth Circuit steps in line with the other Circuit Courts of Appeals on this issue. (See the links below.) It is a formal published opinion, but I am not sure that it breaks any new ground. Barring some future split in the Circuits, I doubt that the Supreme Court will speak on the issue. All that I could say about the issue has been said before.
If readers see anything new in the case or worthy of comment, please make appropriate comments or email me.
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