The Bureau of National Affairs, Inc. v. United States Department
of Justice case brief summary
742 F.2d 1484 (1984)
CASE FACTS
In these cases the court was asked to decide a novel question concerning the scope of the Freedom of Information Act (FOIA): whether appointment calendars, phone logs, and daily agendas of government officials were agency records subject to disclosure under FOIA.
DISCUSSION
The court concluded that appointment materials that were created solely for an individual's convenience, that contained a mix of personal and business entries, and that could be disposed of at the individual's discretion were not agency records under FOIA. The court also held that non-binding budgetary recommendations submitted by a federal agency to the Office of Management and Budget were protected from disclosure under Exemption 5 of FOIA. Accordingly, the court affirmed in part and reversed in part the district court's order in the first case and reversed the district court's order in the second case.
OUTCOME
The court affirmed in part the order that granted the government's motion to compel and reversed the district court's order as to daily agendas. The court held that appointment materials were not agency records under FOIA and that non-binding budgetary recommendations were protected from disclosure under FOIA.
Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)
742 F.2d 1484 (1984)
CASE SYNOPSIS
Appellants, organizations which sought
disclosure of government documents, and appellant United States
government, both sought review of separate decisions from the United
States District Court for the District of Columbia, which granted the
government's motion for summary judgment and dismissed a complaint
seeking to compel disclosure of certain government materials in one
case and which ordered release of documents in the other case.CASE FACTS
In these cases the court was asked to decide a novel question concerning the scope of the Freedom of Information Act (FOIA): whether appointment calendars, phone logs, and daily agendas of government officials were agency records subject to disclosure under FOIA.
DISCUSSION
The court concluded that appointment materials that were created solely for an individual's convenience, that contained a mix of personal and business entries, and that could be disposed of at the individual's discretion were not agency records under FOIA. The court also held that non-binding budgetary recommendations submitted by a federal agency to the Office of Management and Budget were protected from disclosure under Exemption 5 of FOIA. Accordingly, the court affirmed in part and reversed in part the district court's order in the first case and reversed the district court's order in the second case.
OUTCOME
The court affirmed in part the order that granted the government's motion to compel and reversed the district court's order as to daily agendas. The court held that appointment materials were not agency records under FOIA and that non-binding budgetary recommendations were protected from disclosure under FOIA.
Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)
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