October 12, 2011
US Department of Justice v. Reporter’s Committee for Freedom of the Press (1989)
Posted by Asia Rapai under Case BriefsNo Comments
1. Facts of Case
The U.S. Supreme Court case of U.S. Department of Justice v. Reporter’s Committee for Freedom of the Press (1989) started in the District Court but was then taken to the Court of Appeals for the District of Columbia Circuit and finally to the Supreme Court where a decision was made March 22, 1989. A CBS news correspondent and the Reporters Committee for Freedom of the Press filed suit in the District Court seeking the rap-sheet for a man named Charles Medico and his three brothers as it contained “matters of public record.” Medico’s family company had previously been identified as a legitimate business dominated by organized crime figures and had allegedly done work with a corrupt congressman. Respondents said that any information regarding “a record of bribery, embezzlement or other financial crime” would potentially be a matter of special public interest.
They decided to sue after the FBI denied their requests under the Freedom of Information Act. This information would have provided criminal identification records on millions of people and descriptive information as well as a history of arrests, charges, convictions and incarcerations. It was argued that Medico’s record of financial crimes would be of public interest. The District Court ruled that the rap-sheet was protected by Exemption 7(C) of FOIA. It excludes information compiled for law enforcement purposes where production of these records could be expected to cause an unwarranted invasion of personal privacy. When it was taken to The Court of Appeals, it was reversed and ruled that district courts should limit themselves to making factual determinations by finding whether the subject’s privacy is of bigger importance than the public interest because the original information is public record. When the case was heard again by the Supreme Court, the Court of Appeals ruling was then reversed as it was determined that the interest in people’s personal privacy will always be high and that it is protected by Exemption 7 (C).
2. Legal Issue
The legal issue is with this case is the idea of what makes information private versus what makes it public record. It deals with protecting privacy and restricting the distribution of government information. This case asks: Has a legitimate privacy interest of the subject in his rap-sheets faded because they appear on the public record? What types of government information should be public record?
3. Decision
The Supreme Court reversed the Court of Appeals ruling and stated that personal privacy must be protected and shouldn’t be considered public record. A request for law enforcement records or information about citizens can be seen as invading a person’s privacy. Requesting information must be for a purpose and must deal with finding official information about the government agency, for example, instead of information that is just stored by the government agency.
4. Analysis
The court made the decision that protects personal privacy. In the case at the Court of Appeals, public record took more precedent because it seemed to be what was in the public’s best interest, but at a closer look, the court examined the rights of the individual people this could affect and said the affects on these people could not be measured against the public interest. Their rights needed to be more consistently protected than that. This case helped to more clearly define what is and isn’t public record.
5. Questions
1. What is the significance of this case?
2. Do you think there are cases where public interest should be more important than personal privacy?
3. What are other restrictions of the government on information that would seem to be public record?