United States Department of Justice v. Reporters Committee for Freedom of the Press

Exemption 7(C) protects law-enforcement records when disclosure could reasonably be expected to cause an unwarranted invasion of personal privacy. The Court read personal privacy to include an individual's interest in controlling dissemination of information about himself, not merely an interest in keeping facts completely secret. A fact can have been disclosed at one time without losing all privacy protection against later and wider dissemination.

The Court distinguished isolated public records from a rap sheet's consolidated account. There is a major practical difference between locating separate records through diligent searches of courthouses, archives, and police stations and obtaining a single indexed, computerized history from a federal clearinghouse. This difference—the preservation of “practical obscurity”—creates a meaningful privacy interest in the compilation itself.

Federal statutes, FBI regulations, and state practices reinforced that conclusion. Congress and the FBI authorized release of rap-sheet information only in defined circumstances, and most States restricted public access to criminal-history summaries. Those limits reflected a general understanding that centrally compiled criminal histories carry serious privacy consequences.

The Court also relied on its prior recognition that computerized data banks magnify the dangers of disclosure. A centralized file can preserve embarrassing or harmful information long after individual events would otherwise be forgotten, and easy access makes broad dissemination far more likely. Thus, the privacy interest in an FBI rap sheet is substantial.

FOIA gives every requester the same disclosure right regardless of identity or personal purpose. The Reporters Committee's journalistic interest therefore could not receive special weight; if the press could obtain Medico's rap sheet, so could a neighbor, employer, creditor, or any other member of the public.

FOIA's basic purpose is to open agency action to public scrutiny—to show citizens what their government is doing. Information that reveals how an agency performs its statutory duties serves that purpose. By contrast, files that merely contain personal information about a private citizen generally reveal little or nothing about the conduct of the agency holding them.

Medico's alleged relationship with a corrupt Congressman and his company's defense contracts did not change the analysis. His rap sheet might supply details for a news story, but it would not itself reveal how the Department of Justice, the Department of Defense, or any other agency acted. A request for records about the awarding or administration of the defense contracts could implicate FOIA's core purpose; a request for Medico's criminal history did not.

The fee-waiver provision confirmed this reading. It defines a public-interest disclosure as one likely to contribute significantly to public understanding of government operations or activities. That formulation supports treating the interest in a private individual's criminal history as outside the public interest that offsets privacy under Exemption 7(C).

The Court held that FOIA's requirements of de novo review, segregability, in camera inspection, and an agency burden of proof do not invariably require individualized balancing. Those procedures can operate consistently with a categorical rule where an entire class of records predictably presents the same balance of interests.

The language of Exemption 7(C) did not compel ad hoc analysis. A court may determine whether rap sheets as a category are law-enforcement records whose production could reasonably be expected to cause an unwarranted invasion of privacy, just as it may determine whether an individual record qualifies.

For a private citizen's FBI rap sheet, the relevant balance predictably favors nondisclosure. The individual's privacy interest in maintaining practical obscurity is at its strongest, while the FOIA-based public interest is at its weakest when the request seeks only information the Government happens to possess rather than evidence of governmental operations. A categorical rule therefore produces a workable and appropriate result.

Because this categorical application of Exemption 7(C) resolved the case, the Court did not decide whether Exemption 6 independently protected the rap sheet. The Department had also not renewed its Exemption 3 argument before the Supreme Court.