A ruling by a three-judge panel at the U.S. Court of Appeals for the Eleventh Circuit last week could have a significant impact on future trial litigation in Georgia, Florida and Alabama, as courts may consider documents not originally referenced in complaints in requests to dismiss a case with prejudice, one litigator explained.

Prior to the Eleventh Circuit's July 12 opinion, federal trial courts have required that a document be included or attached to the plaintiff's complaint. However, the court's recent opinion, written by Judge Elizabeth Branch, eschewed that in dismissing a civil rights case that some believe could set a precedent for more frequent dismissals of cases before summary judgment.