The Fourth Circuit rejected requests to unseal documents obtained from Twitter, Inc., obtained during a criminal investigation into the unauthorized release of classified documents to WikiLeaks.org.  In re 2703(d) Application, No. 11-5151 (4th Cir. Jan. 25, 2013).  Styled as a petition for mandamus, the court considered whether a public right of access existed for orders and related documents obtained under 18 U.S.C. § 2703(d) of the Stored Communications Act of 1986, Pub. L. No. 99–508, 100 Stat. 1848, 1868 (codified at 18 U.S.C. §§ 2701-2711).  During the pre-grand jury, ongoing WikiLeaks investigation, the government obtained a magistrate order under § 2703(d), which directed Twitter to disclose communications and information from several of its subscribers.  That order was later unsealed, upon the government’s motion, and certain subscribers then moved to unseal the government’s application for the order, documents produced pursuant to the order, and any related § 2703(d) orders.  The subscribers argued that a public right of access existed under the First Amendment and/or the common law.  The Fourth Circuit concluded that there is no First Amendment right to access § 2703(d) orders.  Further, moved by the weight of the countervailing interests under the common law − i.e., notwithstanding the presumption of access and the public interest in openness − the integrity of the government’s investigation and the sensitive facts at issue justified sealing the documents.