In 1980, Congress created the Eleventh Circuit Court of Appeals from the Fifth Circuit Court of Appeals. The newly created Eleventh Circuit included Alabama, Florida, and Georgia, each consisting of three district courts. In Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981), the Court held that Fifth Circuit decisions up to September 1981 would be binding in the Eleventh Circuit. Neither the Fifth nor the Eleventh Circuit, however, have produced a great deal of caselaw discussing the reporter's privilege.