OCTOBER TERM, 1993
Syllabus
certiorari to the united states court of appeals for the fifth circuit
No. 92-1223. Argued November 8, 1993—Decided February 23, 1994
Two local unions filed unfair labor practice charges with respondent Federal Labor Relations Authority after petitioner federal agencies refused to provide them with the home addresses of agency employees in the bargaining units represented by the unions. The Authority concluded that the Federal Service Labor-Management Relations Statute (Labor Statute) required the agencies to divulge the addresses and rejected petitioners' argument that such disclosure was prohibited by the Privacy Act of 1974. The Court of Appeals granted enforcement of the Authority's disclosure orders. It agreed that the Privacy Act did not bar disclosure because disclosure would be required under the Freedom of Information Act (FOIA). In determining that FOIA Exemption 6— which exempts from disclosure personnel files "the disclosure of which would constitute a clearly unwarranted invasion of personal privacy"— did not apply, the court balanced the public interest in effective collective bargaining embodied in the Labor Statute against the employees' interest in keeping their home addresses private. It thereby rejected the view that, under Department of Justice v. Reporters Comm. for Freedom of Press, 489 U. S. 749, the only public interest to be weighed in the analysis is the extent to which FOIA's central purpose of opening agency action to public scrutiny would be served by disclosure.
Held: The Privacy Act forbids the disclosure of employee addresses to collective-bargaining representatives pursuant to requests made under the Labor Statute. Pp. 492-504. (a) Department of Justice v. Reporters Comm. for Freedom of Press, supra, reaffirms several basic principles that have informed the Court's interpretation of FOIA: (1) in evaluating whether a request for information lies within the scope of an exemption that bars disclosure when it would amount to an unwarranted invasion of privacy, a court must balance the public interest in disclosure against the interest Congress intended the exemption to protect; (2) the only relevant public interest to be weighed in this balance is the extent to which disclosure would serve FOIA's core purpose of contributing significantly to public understanding of the Government's operations or activities; and (3) whether an
487
Page: Index 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: October 4, 2007