CPSC v. GTE Sylvania, Inc.

Supreme Court of United States
447 U.S. 102 (1980)

ELI5:

Rule of Law:

The procedural requirements of § 6(b)(1) of the Consumer Product Safety Act, which mandate notice to manufacturers and checks for accuracy and fairness, apply to all public disclosures of information by the Consumer Product Safety Commission, including those made in response to Freedom of Information Act requests. This section qualifies as a withholding statute under FOIA Exemption 3.

Facts:

The Consumer Product Safety Commission (Commission) collected various accident reports related to consumer products from manufacturers, including GTE Sylvania, Inc.
Many of these reports were submitted by the manufacturers with claims of confidentiality.
The Consumers Union of the United States, Inc., and the Public Citizen's Health Research Group submitted requests to the Commission under the Freedom of Information Act (FOIA) for the accident reports.
The Commission decided to release the accident reports, including those for which manufacturers had claimed confidentiality, without following the notice, comment, and accuracy-check procedures outlined in § 6(b)(1) of the Consumer Product Safety Act.

Procedural Posture:

GTE Sylvania, Inc., and other manufacturers filed lawsuits in Federal District Court to enjoin the Commission from releasing the accident reports.
The U.S. District Court for the District of Delaware granted summary judgment for the manufacturers and permanently enjoined the Commission from disclosing the reports.
The District Court held that § 6(b)(1) applies to FOIA requests and that it qualifies as an exempting statute under FOIA Exemption 3.
The Commission, as appellant, appealed to the U.S. Court of Appeals for the Third Circuit.
The Court of Appeals affirmed the District Court's judgment.
The U.S. Supreme Court granted certiorari to resolve a conflict among the circuit courts.

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Issue:

Does § 6(b)(1) of the Consumer Product Safety Act, which imposes procedural requirements on the Consumer Product Safety Commission before it publicly discloses information, apply to disclosures made in response to a Freedom of Information Act request?

Opinions:

Majority - Mr. Justice Rehnquist

Yes. § 6(b)(1) of the Consumer Product Safety Act applies to disclosures made in response to a Freedom of Information Act request. The plain language of the statute, which governs the 'public disclosure of any information,' does not distinguish between agency-initiated disclosures and disclosures made pursuant to an FOIA request. The CPSA contains a list of specific exceptions to the § 6(b)(1) requirements, and disclosures under FOIA are not included in that list. Furthermore, the legislative history indicates that Congress's purpose was to protect manufacturers from the reputational harm of inaccurate disclosures, a risk that exists regardless of how the disclosure is initiated. Finally, § 6(b)(1) qualifies as a withholding statute under FOIA Exemption 3 because it establishes specific criteria for withholding—namely, that the agency must take reasonable steps to assure accuracy and fairness—meaning there is no insoluble conflict between the CPSA's procedural requirements and FOIA's disclosure mandate.

Analysis:

This decision clarifies the relationship between agency-specific disclosure statutes and the general requirements of the Freedom of Information Act. By holding that the CPSA's procedural safeguards qualify as an Exemption 3 statute, the Court affirmed that Congress can create specific, stricter disclosure regimes for certain types of sensitive information that override FOIA's default presumption of immediate release. This precedent strengthens the power of specific statutory schemes to control the release of information, ensuring that other policy goals, such as protecting manufacturers from unfair reputational harm, are balanced against the general policy of government transparency. Future cases will look to this decision to determine whether other agency-specific statutes provide sufficiently definite standards to qualify for Exemption 3 status.

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