Fourth Circuit places limits on district court's inherent powers in terrorism case

In United States v. Moussaoui, the Fourth Circuit considered a district court decision ordering the Government to provide to certain victims of the September 11 attacks (the Civil Plaintiffs) non-public discovery materials that the Government had provided to Moussaoui in the course of its criminal case against him. The Civil Plaintiffs action was not pending before this district court, but rather the Southern District of New York. The panel held that the District Court lacked the inherent authority to issue such an Order:

These cases, however, do not go so far as to suggest that courts have an inherent authority to issue orders that facilitate the judicial process taking place in another case in another jurisdiction. Moreover, it simply cannot be said that the district court’s orders were necessary for the district court’s "orderly and expeditious disposition" of the Government’s criminal prosecution against Moussaoui. Id. Even from the perspective of the civil suits in New York, the district court’s orders were not necessary because Rule 26 of the Federal Rules of Civil Procedure provides for liberal discovery.