Department of Justice v. Reporters' Committee for Freedom of the Press

In Department of Justice v. Reporters' Committee for Freedom of the Press, 489 U.S. 749, 109 S.Ct. 1468, 103 L.Ed.2d 774 (1989), a CBS news correspondent requested the Federal Bureau of Investigation to disclose, pursuant to the Freedom of Information Act, information concerning the criminal records of four members of the Medico family of Philadelphia, a family suspected of ties to organized crime. The FBI complied with the request as to three of the Medicos, each of whom was deceased, but refused the request relating to the fourth Medico. The correspondent brought an action to compel disclosure of the information. The Supreme Court held that the FBI was not required to release the information sought. The Court reaffirmed that the FOIA's (Freedom of Information Act) "basic policy is one of full agency disclosure unless information is exempted under clearly delineated statutory language." 489 U.S. at 773, 109 S.Ct. at 1481. This basic policy, the Court explained, "focuses on the citizens' right to be informed about 'what their government is up to.' " Id. That is, "the FOIA's central purpose is to ensure that the Government's activities be opened to the sharp eye of public scrutiny, not that information about private citizens that happens to be in the warehouse of the Government be so disclosed." Id. at 774, 109 S.Ct. at 1482. "Thus," the Court held, whether disclosure of a private document under Exemption 7(C) is warranted must turn on the nature of the requested document and its relationship to the basic purpose of the Freedom of Information Act to open agency action to the light of public scrutiny, rather than on the particular purpose for which the document is being requested. Id. at 772, 109 S.Ct. at 1481.