United States Department of Defense v. Federal Labor Relations Authority
127 L. Ed. 2d 325, 510 U.S. 487, 1994 U.S. LEXIS 1867 (1994)
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Rule of Law:
When evaluating a request for information under the Freedom of Information Act's (FOIA) Exemption 6, the only public interest to be considered is the core purpose of FOIA, which is to shed light on an agency's performance of its statutory duties. Public interests underlying other statutes, such as the promotion of collective bargaining, are not relevant to the FOIA balancing test.
Facts:
- Two local unions, representing federal civil service employees, served as the employees' exclusive collective-bargaining representatives.
- The unions requested that the U.S. Department of Defense and other federal agencies provide them with the names and home addresses of the employees in the bargaining units they represented.
- The federal agencies supplied the employees' names and work stations to the unions.
- The agencies refused to release the employees' home addresses, citing privacy concerns.
Procedural Posture:
- Two local unions filed unfair labor practice charges with the Federal Labor Relations Authority (FLRA) after federal agencies refused to provide employee home addresses.
- The FLRA, as an administrative tribunal, ruled in favor of the unions and ordered the agencies to disclose the addresses.
- The agencies sought review of the FLRA's orders in the U.S. Court of Appeals for the Fifth Circuit.
- A divided panel of the Fifth Circuit granted enforcement of the FLRA's orders, holding that the public interest in collective bargaining outweighed employee privacy interests.
- The U.S. Department of Defense, as petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the disclosure of federal employees' home addresses to their collective-bargaining representative constitute a 'clearly unwarranted invasion of personal privacy' under Exemption 6 of the Freedom of Information Act, thereby making their release prohibited by the Privacy Act?
Opinions:
Majority - Justice Thomas
Yes, the disclosure of federal employees' home addresses constitutes a 'clearly unwarranted invasion of personal privacy' under FOIA's Exemption 6. To determine if a disclosure is a 'clearly unwarranted invasion of personal privacy,' a court must balance the employees' privacy interest against the public interest in disclosure. Following the precedent set in Department of Justice v. Reporters Comm. for Freedom of Press, the only relevant public interest in this balancing test is the extent to which disclosure would serve FOIA's core purpose of informing citizens about 'what their government is up to.' Disclosure of home addresses reveals little or nothing about the agency's conduct and therefore serves a negligible FOIA-related public interest. In contrast, employees have a nontrivial privacy interest in controlling the dissemination of their home addresses and avoiding unwanted mail, calls, or visits at home. Because the privacy interest of employees in nondisclosure substantially outweighs the negligible public interest in disclosure, the release is a 'clearly unwarranted invasion of personal privacy' under FOIA Exemption 6 and is therefore prohibited by the Privacy Act.
Concurring - Justice Souter
The majority opinion correctly resolves the relationship between the Labor Statute and the Freedom of Information Act exception at issue. However, this opinion should be understood as not resolving the potential applicability of other Privacy Act exceptions, such as the 'routine use' exception, which were not before the Court.
Concurring - Justice Ginsburg
While concurring in the judgment, the Court's precedent in Reporters Committee compels this result, even though it appears contrary to congressional intent in the Labor Statute. Before Reporters Committee, courts consistently held that the public interest in collective bargaining outweighed the privacy interests and required disclosure. Reporters Committee, however, narrowly defined the 'public interest' under FOIA to only include opening agency action to public scrutiny, a definition not explicitly found in FOIA's text. This restrictive interpretation creates a disparity between public and private sector unions, as the latter are routinely entitled to such information. Although this outcome is anomalous, the principle of stare decisis in statutory interpretation requires adherence to the Reporters Committee precedent, leaving it to Congress to correct the disparity.
Analysis:
This decision significantly narrows the scope of the 'public interest' that can be considered in a FOIA Exemption 6 balancing test. It solidifies the precedent from Reporters Committee, making clear that courts cannot 'import' public interest considerations from other statutes, like the Federal Service Labor-Management Relations Statute, into the FOIA analysis. The ruling establishes that the FOIA analysis is self-contained, focusing exclusively on government transparency. This creates a high bar for requesters seeking personal information, as they must now demonstrate that the disclosure directly illuminates government operations, not merely that it serves a different, Congressionally-recognized public good.
