Department of Justice v. Reporters Committee for Freedom of the Press case brief

Department of Justice v. Reporters Committee for Freedom of the Press case brief summary
489 U.S. 749 (1989)

CASE SYNOPSIS

Respondent news groups sought a rap sheet containing criminal records of certain family members under the Freedom of Information Act (FOIA) from the U.S. Department of Justice. On rehearing, the United States Court of Appeals for the District of Columbia Circuit modified its original reversal of the district court's grant of summary judgment in favor of the department and remanded to the district court. The department was granted certiorari.

CASE FACTS
The court addressed whether disclosure of the rap sheet constituted an unwarranted invasion of privacy within the meaning of 5 U.S.C.S. § 552(b)(7)(C).

DISCUSSION

• The court held that the fact that an event was not wholly "private" did not mean that an individual had no interest in limiting its disclosure. 
• The privacy interest in a rap sheet was substantial. 
• Whether an invasion of privacy was warranted had to turn on the nature of the requested document and its relationship to the basic purpose of the FOIA, which focused on the citizen's right to be informed about the government's actions. 
• The news groups in this case did not intend to discover anything about the conduct of the agency, and response to the request would not shed any light on the agency's conduct. 
• Thus, the public interest in release of a rap sheet was not the type of interest protected by the FOIA. 
• The court held, as a categorical matter under § 552(b)(7)(C), that a third party's request for law enforcement records about a private citizen could reasonably be expected to invade that citizen's privacy, and that when the request sought no official information about the government, the privacy invasion was unwarranted.

OUTCOME

The judgment of the court of appeals was reversed.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
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