Federal Bureau of Investigation v. Abramson case brief

Federal Bureau of Investigation v. Abramson case brief summary
456 U.S. 615 (1982)

CASE SYNOPSIS

Respondent journalist sought to enjoin the Federal Bureau of Investigation (FBI) from withholding information requested pursuant to the Freedom of Information Act (FOIA), 5 U.S.C.S. § 552. The district court granted the government's motion for summary judgment. The journalist appealed to the United States Court of Appeals for the District of Columbia, which reversed. The government petitioned for a writ of certiorari, which the Court granted.

CASE FACTS
The journalist sought to obtain material withheld from a single document consisted of a one-page memorandum together with about 63 pages of name check summaries and attached duplicates of original records compiled for law enforcement purposes. The name check summaries were culled from existing FBI files, on 11 public figures, and were not compiled for law enforcement purposes.

DISCUSSION

• The court set out to determine whether information originally compiled for law enforcement purposes lost its Exemption 7 (5 U.S.C.S. § 552(b)(7)), of the Freedom of Information Act, 5 U.S.C.S. § 552, protection if summarized in a new document not created for law enforcement purposes. 
• At the outset, the Court determined and the parties agreed that the information, which the journalist sought from the FBI, was originally compiled for law enforcement purposes. 
• The court held that the duplicate records attached to the name check summaries, though not reproduced verbatim, did not lose their Exemption 7 privilege by being included in a later compilation made for political purposes.
• The government presented sufficient evidence that release of the documents would cause one of the harms listed in the exemption.

OUTCOME
The court reversed the reversal of the grant of summary judgment in favor of the FBI. The court held that the agency had demonstrated that if the documents were released, one of the enumerated harms would occur.



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