Federal Bureau Of Investigation v. Abramson

456 U.S. 615 (1982)


Abramson (P) was a professional journalist interested in the extent to which the White House used the FBI and its files to obtain derogatory information about political opponents. P filed an FOIA request for specific documents concerning particular individuals who had criticized the administration in 1969. The FBI denied the request according to FOIA exemptions 6 and 7C. P appealed to the agency. That was denied, and P filed suit to enjoin the FBI from withholding the requested records. The FBI then provided P with information and P modified his request down to a single document consisting of a one-page memo from J. Edgar Hoover to John D. Ehrlichman together with 63 pages of name check summaries and attached documents. The name check summaries contained data from existing FBI files on 11 public figures. The court found that the FBI failed to meet its burden that the information gathered was for law enforcement purposes but nonetheless ruled that 7C applied and that disclosure would constitute an unwarranted invasion of personal privacy. The Court of Appeals reversed.