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During Watergate, the DC District Court relied on its inherent authority, rather than an enumerated exception to Rule 6(e), to send grand jury materials to the Hill. In an unrelated case, the DC Circuit just invalidated the inherent authority rationale. lawfareblog.com/document-dc-ci…
This DC Circuit opinion adds to the difficulty of obtaining consent to the disclosure of Mueller grand jury materials from the DC District. It’s a difficulty that would be alleviated somewhat if the request was couched as part of an impeachment inquiry.
Sri Srinivasan’s dissent frames the issue clearly. 
