There was apparently little substantive disagreement among the three Eleventh Circuit judges who last week sided with Blue Cross and Blue Shield in a dispute with three doctors who had sought to join a class action against the insurers years after settling similar claims and agreeing to broad releases.

Should the doctors be permitted to set aside those releases? No. In an unpublished, one-sentence ruling issued April 5 by the U.S. Court of Appeals for the Eleventh Circuit, Judges Gerald Tjoflat, Julie Carnes and Senior Judge Ronald Lee Gilman, sitting by appointment from the Sixth Circuit, affirmed the trial judge's “thorough and well-reasoned order” dismissing the case in 2013.

But Tjoflat had more to say, and his 18-page special concurrence prompted a dialectical detour into the objectives and limitations of declaratory judgment actions.