United States Department Of Defense v. Federal Labor Relations Authority

510 U.S. 487 (1994)

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Nature of the Case

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Facts

Two local unions requested that Department (Ds) provide them with the names and home addresses of the agency employees in the bargaining units represented by the unions. The agencies supplied the unions with the employees' names and work stations but refused to release home addresses. The unions filed unfair labor practice charges with Authority (P), in which they contended that the Federal Service Labor-Management Relations Statute required Ds to divulge the addresses. The Labor Statute generally provides that agencies must, 'to the extent not prohibited by law,' furnish unions with data that are necessary for collective-bargaining purposes. Ds argued that disclosure of the home addresses was prohibited by the Privacy Act of 1974 (Privacy Act), 5 U.S.C. § 552a. P rejected that argument and ordered Ds to divulge the addresses. A divided panel of the United States Court of Appeals for the Fifth Circuit granted enforcement of P's orders. The court observed that FOIA, with certain enumerated exceptions, generally mandates full disclosure of information held by agencies. The court stated that only one of the enumerated exceptions -- the provision exempting from FOIA's coverage personnel files 'the disclosure of which would constitute a clearly unwarranted invasion of personal privacy,' 5 U.S.C. § 552(b)(6) (Exemption 6) -- potentially applied to this case. The Fifth Circuit balanced the public interest in effective collective bargaining embodied in the Labor Statute against the interest of employees in keeping their home addresses private. The Reporters Committee case held that only public interest to be weighed in the Exemption 6 balancing analysis is the extent to which FOIA's central purpose of opening agency action to public scrutiny would be served by disclosure. The majority held that when Reporters did not apply to the situation that arises when disclosure is initially required by some statute other than the FOIA, and the FOIA is employed only secondarily. The court ruled that 'it is proper for the federal court to consider the public interests embodied in the statute which generates the disclosure request.' The court reasoned that the weighty interest in public sector collective bargaining identified by Congress in the Labor Statute would be advanced by the release of the home addresses, disclosure 'would not constitute a clearly unwarranted invasion of privacy.' The Supreme Court granted certiorari.