Chrysler Corporation v. Brown case brief summary

Chrysler Corporation v. Brown case brief summary
441 U.S. 281 (1979)

CASE SYNOPSIS

Petitioner sought review of a decision of the United States Court of Appeals for the Third Circuit holding that petitioner had no private right of action to enjoin agency disclosure under the Freedom of Information Act (FOIA) and the requested disclosure was authorized by law within the meaning of Trade Secrets Act, 18 U.S.C.S. § 1905.

CASE FACTS
Petitioner sought review of a decision of lower court holding that petitioner had no private right of action to enjoin agency disclosure under the FOIA and that the requested disclosure was authorized by law within the meaning of the statute.

DISCUSSION:

• The Court agreed with the lower court's judgment finding that the FOIA was purely a disclosure statute affording petitioner no private right of action to enjoin agency disclosure but disagreed with lower court's judgment that disclosure was authorized by law within meaning of § 1905. 
• The Court held that the basic objective of the FOIA was disclosure and that the FOIA exemptions were not a mandatory bar to disclosure.
• Congress did not limit an agency's discretion to disclose information when it enacted the FOIA; thus, the FOIA did not afford petitioner a right to enjoin agency disclosure. 
• In addition, § 1905 did not afford petitioner a private right of action to enjoin disclosure in violation of the statute. Section 1905 was intended to address formal agency action. 
• The Court concluded that the regulations did not provide the authorization required by statute because they were not substantive rules having the binding effect of law.

OUTCOME

• The Supreme Court vacated the lower court judgment and held that neither the FOIA nor the Trade Secrets Act provided petitioner with a private right of action to enjoin agency disclosure. 
• The agency had discretion under the FOIA to disclose information and the FOIA exemptions were not a mandatory bar to disclosure. 
• In addition, agency regulations were not substantive rules having binding effect of law required by the Trade Secrets Act.

Recommended Supplements for Administrative Law
Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)