What is the legal test for disclosing transcripts from a grand jury?

The decision whether to disclose grand jury transcripts is within the district court's discretion. United States v. Walczak, 783 F.2d 852, 857 (9th Cir.1986). Disclosure "may not be ordered unless the defendant demonstrates with particularity the existence of a compelling need that is sufficient to outweigh the policy of grand jury secrecy." United States v. DeTar, 832 F.2d 1110, 1113 (9th Cir.1987). An appellant's speculation that prosecutorial misconduct occurred before the grand jury does not justify disclosure. Id.