GTE Sylvania, Inc. v. Consumers Union of the United States, Inc.

Background

Consumer groups (Consumers Union and Public Citizen) asked the Consumer Product Safety Commission (the consumer safety agency) for television accident reports under the Freedom of Information Act (FOIA). Television manufacturers had given many of those reports to the agency and claimed they were confidential. A federal court in Delaware granted the manufacturers an injunction (a court order forbidding release) and later a permanent injunction blocking disclosure. The consumer groups then sued the agency in Washington, D.C., seeking the same documents under FOIA while the Delaware injunction remained in place.

Reasoning

The core question was whether the agency was “improperly” withholding records under FOIA when it could not produce them because a different federal court had enjoined disclosure. The Court explained that FOIA allows courts to order production only where an agency is improperly withholding records. Here the agency had no discretion to release the material because it was obeying a valid court order. The Court relied on FOIA’s history and ordinary respect for judicial decrees to conclude the agency was not improperly withholding the reports simply by following the Delaware injunction.

Real world impact

The ruling means agencies subject to valid federal injunctions need not disclose records under FOIA while those injunctions stand. Requesters who were not parties to the earlier suit cannot force disclosure if the agency is obeying another court’s order. The decision protects court decrees and limits FOIA claims when compliance would require an agency to defy a separate federal court order.