Central Intelligent Agency v. Sims

471 U.S. 159 (1985)

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Nature of the Case

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Facts

Sims filed a request with the CIA seeking certain information about MKULTRA. The CIA made available to Sims all of the MKULTRA grant proposals and contracts. However, under Exemption 3, the Agency refused to disclose the names of all individual researchers and 21 institutions. The Agency relied on 50 U.S.C. Section 403(d)(3) which gave the Director responsibility for protecting intelligence sources and methods from unauthorized disclosure. Sims filed suit under the FOIA section 552(a)(4)(B). The district court ordered disclosure of the withheld names. The Court of Appeals remanded the case to the district court because the analysis of the statute under the FOIA lacked a coherent definition of intelligence sources (see definition on page 1167 Cass 3rd). The district court applied the definition and ordered the Agency to disclose the names once again. The Appeals Court affirmed that part of the lower court's holding exempting from disclosure the institutional affiliations of individual researchers found to be intelligence sources. It reversed the court's ruling with respect to which individual researchers satisfied the need for confidentiality aspect of its formulation of exempt intelligence sources. The Supreme Court granted certiorari.