Federal Communications Commission v. AT&T Inc.
Headline: Court rules corporations cannot claim 'personal privacy' under FOIA’s law-enforcement exemption, allowing greater disclosure of corporate investigation records and limiting corporate privacy claims in public records requests.
Holding: The Court held that FOIA Exemption 7(C)’s protection for law-enforcement records that would invade "personal privacy" does not apply to corporations, so companies cannot claim that exemption to block those records.
- Corporations cannot use FOIA’s 'personal privacy' exemption to block law-enforcement records.
- Makes it easier for competitors, journalists, and public to access corporate investigation files.
- Individual employees named in documents still may be protected from disclosure.
Summary
Background
A major phone company, AT&T, voluntarily reported possible overcharges in a government program and provided the Federal Communications Commission with invoices, emails, personnel names, and other documents in an investigation. A trade association asked the FCC for the agency’s investigation file under the Freedom of Information Act (FOIA). The FCC and its Enforcement Bureau protected some commercial data under a different FOIA exemption and said that Exemption 7(C) — the law-enforcement privacy rule — applied to individual people named in the documents but not to AT&T as a company. The Third Circuit disagreed and said a corporation can have "personal privacy," so it ordered disclosure protection for AT&T in this context.
Reasoning
The central question was whether the phrase "personal privacy" in FOIA Exemption 7(C) covers corporations. The Court rejected AT&T’s argument that the statutory definition of the noun "person" automatically makes the adjective "personal" apply to corporations. The opinion explains that "personal" ordinarily refers to human, individual concerns and that Congress used the same phrase earlier in a provision understood to protect individuals. The Court also relied on dictionary meanings, historical legal commentary, and a Department of Justice interpretation to conclude that "personal privacy" evokes individual human interests, not corporate interests. The Court therefore reversed the Third Circuit.
Real world impact
As a result, companies cannot use FOIA Exemption 7(C) to shield law-enforcement investigation records by claiming "personal privacy" for the corporation. Individual employees and others named in documents may still claim privacy protection. This ruling changes how agencies, companies, competitors, and the public will approach requests for investigative records.
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