Lawfare Archive: Anna Bower on Judge McBurney’s Deliberations

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Things are really heating up in the country's smallest house. Dad! Squealed me a mouse. We could save around £100 by setting the boiler-float temperature to 60 degrees. I'll turn and radiate his down in rooms we've done years. Interrupted Mo? Turn him down. Not off, said Mia. Plus finding and blocking drafts. Said Mo, should save enough to increase our allowance? A little saves a lot. You could save around £100 a year of your energy bills with three tips at gov.uk slash clean energy. I'm Marissa Wong, Internet Law Fair. With an episode from the Law Fair Archive for February 7th, 2026. On January 28th, the FBI raided an election office in Fulton County, Georgia and seized documents and ballots from the 2020 presidential election. The raid appears to be part of the Trump administration's larger effort to find evidence supporting the claim that the 2020 election was, quote, stolen, unquote, from President Trump through voter fraud and unverified ballots. Fulton County, Georgia, is also one of the jurisdictions where President Trump was indicted in 2023 following an eight-month investigation into his attempts to overturn the election result. For today's archive, I chose an episode from January 25th, 2023, in which Anna Bauer joined Benjamin Woodis to discuss Judge Robert McBurnie's hearing on the release of the Fulton County Special Grand Juries report on the 2020 election interference case against Donald Trump, including arguments made by the District Attorney and Media Organizations, Judge McBurnie's reactions, the future of the Special Grand Juries report, and one. I'm Benjamin Woodis and this is the Law Fair Podcast January 25th, 2022. Judge Robert McBurnie of the Superior Court of Fulton County held a hearing on Tuesday to decide whether or not to release the Fulton County Special Grand Juries report on 2020 election interference case against Donald Trump. The decision-interference in Georgia, our own Anna Bauer, was in the room live blogging the matter and I caught up with her from the courthouse right after the hearing to talk it through. Why did the District Attorney argue that the report should continue to be sealed for now? What were the media organizations, arguments, and which way was Judge McBurnie leaning? Is the report going to become public? And if so, when? It's the Law Fair Podcast January 25th, Anna Bauer on Judge McBurnie's deliberations. So Anna, give us a little background to start with about the hearing that you just attended, where you are, and why this hearing took place. Sure Ben, so on January 9th, on the morning of January 9th, Judge Robert McBurnie, who has been overseeing the Special Purpose Grand Jury investigation into 2020 election interference in the state of Georgia issued an order announcing that the Special Purpose Grand Jury was now dissolved, that its work was complete, and that it had issued a report. And the Grand Jury is recommended that the report be published under a statutory provision called 151280, which is a provision that requires a judge to publish something called a general presentment of a grand jury, if the grand jury recommends publication. And in McBurnie's January 9th order, he noted that there was an unresolved question of whether or not this report constitutes a presentment, because if it is a presentment, then he would be required under state law to publish the report. So he set this hearing for January 24th, which is the hearing that I went to today, and he invited the district attorney to present argument on whether or not the report should be published or whether it should not be. And then he also invited any media organizations to intervene and provide their perspective as well. So today we heard argument both from the district attorney and from media interveners as well. So let's unpack this. So you have a special grand jury investigation, and this is of course the investigation of the 2020 election meddling in Georgia. You have a grand jury final report, and for those listeners who don't remember this, the grand jury only issues a report. It can recommend indictments, but it can't bring them. So the report presumably includes whatever recommendations the grand jury has made for indictments. Is that fair? Yes, that's fair. So if if Fannie Willis is going to indict Donald Trump, it probably is reflected somehow in that document. Probably, though, I mean, I think that it's fair to say as well that it's within the scope of the district attorney's discretion to either seek indictments that are not included in that report. And for the court, she could choose a strategy that does not reflect the potential indictments that the grand jury did recommend. So for example, if the grand jurors went with a number of indictments that for example reach Rico charges in Georgia, the district attorney might disagree and say, I want to go with something more narrow and scope. I think that's fair to say that the grand jury is not going to be in the scope of the grand jury's discretion. But for the most part, you know, if indictments are recommended in that report, I do think it's fair to say that that likely reflects at least some of the charging decisions that the district attorney could make. So high stakes case before Judge McBerney this morning and it all comes down to as best as I can tell one or maybe two piquet un points of Georgia criminal law, which is to say, is this document a general presentment? Or is it a court document within the meaning of rule 21 of the Georgia rules of criminal procedure? Is that fair? That's right. And I talk a little bit about this presentment argument in a piece that I wrote for law fair and anyone who's interested in the meanings of presentments, I suggest that you read that piece because it will be much more nuanced than the conversation. I'm sure that we'll have here because presentments are actually kind of hard to talk about because it means a number of different things and has a specific meaning under Georgia law in particular. But I think the important thing here on in that respect, Ben, that that folks listening need to know is that presentments in Georgia law have two different meanings. One is a general presentment, which basically is used kind of interchangeably with reports and then the other type of presentment is something called a special presentment, which is kind of like a formal charging instrument, you know, kind of like an indictment that would be used to actually charge an individual with a crime and and that person can then be a reigned on the special presentment. But under Georgia law, there's now really not much distinction between special presentments and indictments. They're functionally the same thing. So if you hear those terms being thrown around, that's kind of the distinction there and part of what the hearing came down to today was the difference between general and special presentments. And then whether or not a report is different from either of those things. So it's all very confusing. All right, so we're going to get to the piquet un points of law momentarily because nerding out on Georgia state criminal procedure law is what we founded law fair to do low those many years ago. But before we do that, let's deal with the news. It seems to me this hearing had two major pieces of news and maybe a third. The first of them is that Fanny Willis said in open court that charging decisions were imminent. I don't want to parse her use of the word imminent as opposed to coming soon. But when I hear the word imminent, I mean don't release this today because I'm going to charge people the day after tomorrow or next week. How did you read her statement on the imminence of charging decisions? Well, I do think that that was notable, but at the same time there were statements that were made by one of the deputy district attorneys who made argument Donald Weekford, who also noted that the district attorney apparently has not had time to incorporate any of the report or to really review thoroughly the report to make a charging decision. I'm not sure how much of that is just lip service to the idea of wanting a judge McBernie to kind of put things on ice for a little while before the report is released. I find it quite hard to believe that the district attorney has not reviewed that report thoroughly, especially considering that the district attorney as the legal advisor of the grand jury likely was very aware throughout the drafting process. What the grand jurors were thinking and writing. So yeah, I mean, unfortunately, I don't have much of an answer for you been other than that. I don't know what imminent means, but it does seem to me based on some of the context and implications in what was said that it seems very, very, very likely that charging decisions are coming and that it will lead to criminal charges being. I mean, one way to understand the district attorney's position in this hearing, which we should spell out was that judgment Bernie should not release the report immediately. We can get we'll get into the details of that is that they're almost ready to go, but not quite. And if he hits the publish button on that document, you know, it just creates concerns with whatever they do that there was somehow prejudice by the publication of the report. So if you can just hold him off by two weeks, the problem goes away or is at least a meal you're rated the other way to think about it is, you know, maybe they are, they have a fair bit more work to do. And they don't want to give tips and leads to people they don't want the prejudice arguments, but you know, imminent means kind of soon, but it doesn't mean in the colloquial sense of imminent like, you know, the finger is on the send button and it's coming down, but it just hasn't hit the button yet. Right. And I don't think there's been some speculation about whether or not maybe presentation of evidence has already started before the regular grand juries that sit in Fulton County. As you said, been earlier, the special grand jury can only issue a report cannot issue indictments. And so what that means for this process is that Fony Willis must present evidence to a regular grand jury to secure indictments. There are two regular grand juries that sit in Fulton County and this term of court, as I understand it, the days are Monday, Tuesday and Thursday, Friday, they have two concurrent grand juries that kind of alternate during different days, the week. I've been watching the indictments coming out of those grand jury rooms each day and it's looks to me like the number of indictments pretty much track with just the normal run of the mill number of indictments that usually come out of the grand jury room. So I would think that if presentation of evidence has started, we would probably see a lower volume of indictments from at least one of those grand juries. So I'm pretty skeptical that that she is already started presenting evidence, which means that we at least have, you know, a few days, if not weeks before indictments would would be brought because presenting evidence, I think will take some time. All right, so the second big piece of news, which we've already alluded to is that the district attorney opposed the release of the report. This sounded a little strange to me when I first heard it, but then kind of was like, well, of course they do. So first of all, the DA's position seems a little bit weird because they asked for the convening of this grand jury, knowing that all it can do is produce a report and that it's up to the grant that can then be published or requested to be published. So why convene a special grand jury if you don't want the report published in a timely fashion was kind of my first question, but then secondly sketch out for us the position that the DA's office took before judgment, Bernie. Right, well, I think first of all, there there's reasons why you would want a special grand jury other than just knowing that they are able to produce a report, right, because a special grand jury can sit for much longer than the two month term of court that a regular grand jury is kind of bound to those grand juries are able to become more familiar with the investigation and you kind of don't have to. To bother with getting a regular grand jury bogged down in a very long complex investigation, but besides that it seems to me that the argument that the district attorney's office was making is that you know it's not that we don't want this report to ever come out, but it's that this is an ongoing criminal investigation. This is a special grand jury that was requested by the district attorney or the executive branch that was kind of used for this investigative criminal purpose. And so as a result, you know, one consideration that should be taken into account is the effect that the release of this report would have on the ongoing criminal investigation. And that effect the district attorney argued is that you know there could be potential prejudice to possible future defendants and they could then in turn use that, you know, as a way to potentially make venue transfer motions or kind of argue that their constitutional rights were in some way violated. And then that in turn could weaken the criminal investigation later down the road. Okay, so the third piece of news, which is maybe a piece and a half and is a matter of interpretation. I'm curious whether you agree with my interpretation is that it sounded to me like judge MacBernie does not buy the idea that there is not an obligation to publish this job. He was very circumspect with what he said, but it felt to me like his body language was saying, I don't see how I get around ordering publication of this under the statute. What did you think of his posture in this hearing? I think that's right. I think that it sounds to me like you and I had the same interpretation of MacBernie's tone and body language and general demeanor. He seemed that he did not really buy the district attorney's arguments. I do think he was sympathetic to their policy arguments. So the idea that this is an ongoing criminal investigation that there's reason to kind of wait as a matter of policy because you don't want to interfere with that investigation. I think that MacBernie's hands are a little bit tied here as a matter of law. And I think that he was right to be quite skeptical about some of the arguments that were made about by the district attorney's office, particularly on the question of whether or not this report constitutes a general presentment under the provision of Georgia law that would require publication, which is a section 151280. In 1983 election, she's won a landslide second. Police have been deployed to disperse crowds as the poll tax riots escalate. Credit crunches continuing to spread from the USA. Britain has left the European Union. I mean this goes on. Boris, please. We've helped Britain invest through 45 years of change. That's why we're the UK's number one investment and savings platform trusted by two million people. 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Get matched with the qualified therapist and start clearing your mental inbox today at BetterHelp. Visit BetterHelp.com slash random podcast for 10% of your first month of online therapy. Let's go into the merits of the argument. Let's bracket for now the media organization's arguments because you can't understand them before you go through the law. So Judge McBernie seemed to be operating on the assumption that there are kind of two ways that this gets released, right? Or that he's bound to release it. One is, as you say, that if it's a general presentment and the other is if it's a court document, there's a presumption of release of public accessibility, although it can be overcome in circumstances. So let's talk about general presentments. How could a non-inditement report from a special purpose grand jury be anything other than a general presentment? It's a good question, Ben, because I really, I mean, I put a lot of thought into it and I do not know how looking at the statute and the case law, you really can distinguish a report from a general presentment. But if I had to give it my best shot at kind of summarizing what the district attorney's argument was, it's that this report has elements of being a general presentment. So that would include, you know, kind of the grand jury's findings and some of there may be more critical remarks that they've made or something like that. I'm not entirely sure because the conversation was very, very vague and broad because there were concerns about, you know, revealing information about what could be or is in the grand jury's report. And on the other hand, there seemed to be some argument that this kind of resembles a special presentment in that there could be accusations of criminal activity within the report and that that would kind of back to what presentments or special presentments used to be under Georgia law, which were, you know, the grand jurors themselves accusing someone as a crime. That then led the district attorney's office to say, well, this means that there are kind of hybrid elements of general presentment, special presentment, and then something else entirely. So this report is kind of a weird third thing that doesn't fall under the statute of being a general presentment and you heard McBernie's, you know, make a joke about, so what is it a hybrid presentment. So, you know, I don't think that that argument was particularly compelling to me, but then I'd be interested to hear if you found it at all compelling. No, I mean, I think their argument basically is this document is a report. It's not either a special presentment or a general presentment, and it may contain both special presentments or general presentments were kind of elements of both. And so what the court should do is evaluate it functionally and boy, it would be really inconvenient for us if the court just ordered its publication, but it didn't seem to be able to cite any examples of a court saying the special grand jury has issued its report. We don't consider the report general presentment, so we're not going to release it. So I think they're my best guess is that they're stalling for time, and they figure if they can get Judge McBernie to spend a week writing an opinion. And then as he suggested, you know, sort of push the, he said he wasn't going to just do anything precipitously that causes the report to dump in public. So if they he spent some time writing an opinion, and then he says, I'm ordering the report released at X and such a day on X and such a time and gives everybody a little bit of grace period, then that will give them some time to, you know, finish up. They're business, but I don't see how a grand jury report is meaningfully distinguishable from a general presentment, not that I've studied Georgia law on general presentments as you have, but I thought the district attorney's arguments, which they have not put in writing. It was an oral there, they presented this position for the first time today in open court. I thought was a little bit bizarre, honestly. Right, and you have to wonder how much of, I mean, the fact that there were no filing. I mean, I know that this is state court. And so sometimes you do have instances where you don't make a filing before and you just go in and you're making just oral argument and representations, but it is quite unusual in my view that the district attorney's office did not make any filings ahead of time. We also heard Donald Wakeford make several suggestions to Judge McBernie that the district attorney's office be given time to provide written briefing. So I do wonder if there is something to this idea that there's a kind of stalling for time or buying time element to all of it. Particularly if you combine it with the DA's comment that decisions are imminent, right? So, you know, maybe the internal discussion at the DA's office is, gosh, we need two weeks. Can you buy us two weeks, Wakeman? Well, I can try, you know, and so she goes in there and says, we need time. Please don't release this. And he makes a kind of treat the special presentment language and the general presentment language and the report language is creating a kind of model and so evaluate it functionally and see what you can do. And the hope is you suck up a couple of weeks. Right. I think that's right. All right. So let's talk about the media organizations position, which was very similar to the view that you articulated in your piece, which is sure looks like a special presentment. And there's a mandatory reporting obligation in the presence of a grand jury's request for a special presentment. Who were the media organizations and what did they argue today? Right. The media organizations included a wide swath of various media organizations and included the Atlanta Journal Constitution, the New York Times, Wall Street Journal. Pretty much all of the large media news organizations that you can think of CBS, I believe CNN, I won't spend time listing all of them, but the arguments boiled down to two things. The first is the arguments that you would I have been talking about throughout this conversation, been about a general presentment and reports under section 151280. Basically, the media organizations took position that we did, which is that there's really no reason to think that Georgia law distinguishes between reports and general presentments. And for that reason, the section 151280 requires publication of this report. But there also was a second argument that they made about a superior court rule called rule 21, which basically provides that there is a presumption of public access to court records, unless you know, some exception by law or under the rule, otherwise provides. And so the media organizations argued that this is indeed a court record and that it should be afforded this presumption of public access. And there was a lot of emphasis on the kind of strong public interest arguments that should be made in terms of the public, you know, having a right to see what this grand jury found out and what they recommended. So as I read Judge McBernie, he was as you said earlier, sympathetic as a policy matter to the idea that, you know, the DA has, you know, important equities in the secrecy with respect to an ongoing investigation, but pretty skeptical that you could treat this either as not a court record. It is, after all, a grand jury report, although they did say that the only copy of it was in possession of the DA. So maybe you could argue that it was a court record once, but it's now a DA record. And that said, I think he seemed pretty skeptical of that. He also, however, seemed to think he might have some latitude to delay or redact the statute does command its publication, but doesn't say it's publication has to be immediate on the grand jury's request. Where do you think he's heading on this? Is it a kind of like, I'm going to order that it be released six months from now that'll give you time to finish up? Is it, I'm going to order it be released today, but we all accept redaction, you know, proposed redactions or is it, you know, some combination of a time delay and a redaction process. Well, first, I think that the redaction question is an important one that was not really covered all that much in the hearing, which I found interesting. But there's a lot of case law on this about the authority of the judge to be able to expand or redact kind of extraneous information that's included in a report by a grand jury or information that is kind of unnecessary because it is embarrassing or or criticizes public officials and that kind of thing. The hearing didn't really get into a lot of that case law, but I would not be surprised if McBerney chooses to kind of use that power to redact and expunge and really examines the content of the report to do that. But in terms of the timing, I don't think it's going to be six months. If there's something that I do know about Judge McBerney from being in his courtroom quite a lot in recent months, it's that he feels very strongly about public access. He more than pretty much any state court judge that I've ever been in a hearing with is very, very concerned about whether or not his livestream is working, whether or not people have access to the courtroom. He kind of always makes that a priority at the beginning of each hearing. And so my inclination just based off of that as well, which I mean isn't really anything other than just like my instinct. I think that he would choose a relatively short period of time. I think that even though he is inclined maybe to be sympathetic to the district attorney's position, I think that he would give her a relatively short period of time if he is going to hold off on publication. So potentially, you know, a matter of weeks and and he might see that as a reasonable amount of time for the district attorney to make a charging decision. So if you are a funny Willis today, less than an hour after the hearing, it seems to me you have a pretty substantial fire lit under your butt, which is to say, you've heard from him the same basic skepticism that you and I both heard. You've heard from him no indication that he's sympathetic to the idea that he can just, you know, deep six the report until you're done. And so you have to operate on the assumption that you have a very limited window of time in which your guaranteed secrecy, right? Don't you have to assume he's going to order it released quickly. Right. I think you do have to assume that in terms of timing, I do think that she wants to act quickly. I will say that there's been some reporting that she potentially has other considerations about something that's called a speedy trial domain deadline. And I won't get into it too much, but basically Georgia has a statutory deadline for speedy trial demand. So once you're indicted, basically, if you make a speedy trial demand, then you have to be tried either within the term of court that you are indicted or the next term after that. So basically that gives the district attorney roughly four months in a typical situation to indict someone and then bring them to trial if they make a speedy trial demand. So there's been some speculation that maybe she would need to wait until the beginning of March when the new term of court starts so that she has as much time between the beginning of the term of court and then the next term of court if a speedy trial demand is brought. I will say that there is an order in Fulton County because of the backlog of COVID cases. That means that basically those deadlines are not applicable right now. So I don't think that that will be a consideration. I do not see what would be stopping the district attorney from bringing evidence to a regular grand jury. You know, this week or next week or that week after, but I certainly think that because of this hearing today and and where McBerney seemed to be leaning, there is more pressure than ever to make a decision very quickly and to present evidence very quickly because if she's betting on that report becoming public and doesn't, you know, want it to be public before she presents evidence and brings indictments. And she's going to have to get moving. Finally, the president's lawyers made a statement yesterday, which I thought was interesting. It may have had some factual claims about his interactions with this special purpose grand jury. So what did the president's lawyers say and how did you read it? The president's lawyers basically said that they would not be participating in any of the arguments before judgment, Bernie today on, you know, whether or not the report should be released. And if it is released in what form, they said that former president Trump has not been asked to appear voluntarily before the special purpose grand jury. And that he was never subpoenaed to appear. What do I make of it? I think it's quite interesting that former president Trump was never asked to appear voluntarily considering some of the language in certain cases in Georgia about special purpose grand juries that have to do with kind of the due process protections afforded to individuals who are named in in a grand jury report. But at the same time, I mean, I think that probably what the calculation there is that if he's asked to voluntarily appear, then he would say no. And if he is subpoena, then it would lead to a very long and drawn out court battle. But I still, I do think it's a potential misstep to not at least ask for voluntary appearance because it at least gives the impression of some kind of due process or opportunity to be heard. But I'd be interested to hear your take on it, Ben. I agree with you. I think it's a, well, if you're planning to bring a case against him, it is, I think, actually unfair not to give him an opportunity to present whatever he wants to present to a grand jury before you indict him. Obviously, there are circumstances in which grand juries don't behave that way and some of them are legitimate. But I think it's always best practice if you can invite somebody to ask questions or questions before the grand jury to do it. Trump's lawyers interpreted this for public purposes anyway as a sign that he's not suspected of anything and that they've cleared him. I don't interpret it that way. I interpret it much closer to the way that you just articulated, which is that it was a decision based on the difficulty of getting him there. If you subpoena him and the likelihood of his agreeing voluntarily. But I do think it's a misstep. And I think it'll be the first, you know, the first item in the president's former president's press release. She goes ahead with a case against him that, you know, a grand jury that's never heard from him, never invited him to testify has brought a case against him. I think it's an unfortunate error if she is in fact planning to bring a case against Trump. And one more thing before we wrap the Donald Trump was not the only person who did not make a submission before the court on the question of publication. In fact, nobody other than the media did. And that includes all of the many witnesses whose conduct may be at issue specifically discussed specifically criticized whose indictments might be specifically recommended by the special purpose grand jury. And not one of them made a submission to the court. Now, do you read this as they weren't invited by Judge McBerney to do so? Or is there some other reason to your mind that, you know, basically we had a, had a court proceeding and nobody came. Well, first it is right that targets in the investigation actually were not specifically invited to make argument in judge McBerney's January 9th order. If you read that order closely, he invites argument from the district attorney and any consolidated media interveners. He does not say targets of the investigation or potential named individuals are also invited to make filings or to provide their perspectives. So it could be that that was interpreted as, you know, we're not invited. I think that maybe the more likely reason is that these individuals didn't have an opportunity to read the report. And so they were unable to really make substantive argument or claims about what specifically should be redacted or expunged. And I think that probably if they do know that there's some kind of damning information that they've said in the grand jury room or that might have been uncovered, you know, you don't want to reveal that by arguing for it to be redacted in the report. So I think that probably it comes down to just the lack of information on the part of potential targets because they didn't have the opportunity to review that report and don't know what's in it. But yeah, I mean, I really don't know in the end what exactly to make of it, but it was interesting that no potential targets made, made arguments. What do you make of it then? I'm really not sure. I guess my gut is consistent with your second theory, which is that people don't really know what's in it and they don't want to draw attention to their own misconduct by saying, hey, there's going to be negative stuff about me in the report. Please don't publish it, which is how any, you know, any Mark Meadows filing would come off. And so I wonder if it's just, hey, if we're quiet, maybe we get lucky and it's all about Donald Trump. If we're loud, we just draw attention to the fact that we had a very difficult interaction with the grand jury. Right. So what happens next to we just sit back and wait for it seems to me the next move is in Fannie Willis's hands. The ball is in Fannie Willis's court. I we don't know what happens next. It could be days. It could be weeks. It could be months until we hear something. But we do know that Judge McBernie says that he will circle back and ask the participants in today's hearing. If he has any additional questions or if there's any additional written filings that need to be made. So we might see some movement there on the public docket. But in terms of actually making charging decisions and bringing those charges and presenting evidence before regular grand jury. It's pretty shrouded in secrecy. So only time will tell. We are going to leave it there and a bowler. Thank you so much for joining us today. Thanks Ben. The Lafayr podcast is produced in cooperation with the Brookings Institution our audio engineer. This episode is me. I'm in a hallway on top of a piano. Literally my I built my little studio on top of a piano in the middle of a hallway in a hotel. I can record a podcast anywhere. You however are the only person who can promote the Lafayr podcast the way it should be promoted. Tell the world about Anna's brilliant thoughts about the special purpose grand jury and the aftermath of its report. The Lafayr podcast is edited by the one the only Jen Pachihau who will receive these audio files and majestically turned them into the finished product that you are hearing. Our music is performed by the only Sophia Jan who has ever played the piano for Lafayr. And as always, thanks for listening. Twilio's customer engagement platform empowers the builders shaping tomorrow. Whether you're launching a startup or transforming an enterprise, Twilio helps you build, test and scale with confidence. Connect data, AI and communication in one seamless platform. No silos, no barriers. Twilio, the ultimate toolbox for customer engagement. Learn more at Twilio.com.