United States Department of Justice v. Reporters Committee for Freedom of the Press
Headline: Ruling lets the FBI keep computerized criminal "rap sheets" private under FOIA, limiting journalists’ public access and making it harder for the public to obtain centralized criminal histories.
Holding: The Court held that FOIA Exemption 7(C) permits agencies to withhold federal compiled criminal "rap sheets" about private citizens when the records do not reveal official government activities, reversing the appeals court.
- Allows FBI to withhold centralized criminal "rap sheets" about private citizens.
- Makes it harder for journalists to obtain federal compiled criminal histories.
- Keeps FOIA focused on government operations, not private individuals' records.
Summary
Background
A CBS reporter and the Reporters Committee asked the FBI for the FBI’s compiled criminal-history file, or “rap sheet,” for one member of the Medico family. The FBI and Justice Department refused. Lower courts disagreed about whether the files must be released under the Freedom of Information Act (FOIA). The Supreme Court agreed to decide whether giving a third party a federal rap sheet could “reasonably be expected” to be an unwarranted invasion of privacy under FOIA Exemption 7(C).
Reasoning
The Court focused on two ideas. First, a federal compilation of arrests and convictions kept in a single, computerized file is different from scattered public records in many local courthouses. That centralization creates a strong privacy interest the opinion calls “practical obscurity.” Second, the central purpose of FOIA is to expose what government agencies are doing, not to give the public private dossiers about ordinary people. Because the request sought a private citizen’s compiled history and not information about government actions, the Court concluded the privacy interest outweighed the limited FOIA public interest and adopted a categorical rule allowing agencies to withhold such rap sheets.
Real world impact
News organizations, private employers, and members of the public will find it harder to obtain centralized FBI rap sheets under FOIA. Congress’ narrow exceptions (for banks, securities regulators, and nuclear licensing) remain in place, and requests about government operations are still favored. The ruling reverses the appeals court and narrows FOIA access to federal criminal compilations.
Dissents or concurrances
Justice Blackmun (joined by Justice Brennan) agreed with the outcome but warned against the Court’s bright-line rule and said some circumstances—for example, a recent conviction by a candidate for public office—might justify disclosure.
Opinions in this case:
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