Prison Legal News v. Charles E. Samuels, Jr.
415 U.S. App. D.C. 354
| D.C. Cir. | 2015Background
- Prison Legal News (PLN) filed a FOIA request in 2003 seeking documents showing money the Bureau of Prisons (BOP) paid in connection with lawsuits and claims (1996–2003); PLN also sought a fee waiver.
- After suit, BOP produced ~11,000 pages with ~2,993 redacted; BOP relied on Vaughn indices and declarations (Moorer Decl., Stroble Vaughn index) invoking FOIA Exemptions 6 and 7(C).
- The district court found BOP’s search adequate and accepted BOP’s categorical justification for redacting names and personal identifying information under Exemption 6, granting summary judgment to BOP.
- PLN appealed, arguing neither Exemption 6 nor 7(C) applied because BOP used an improper categorical approach that failed to weigh privacy vs. public interest for specific individuals and documents.
- The D.C. Circuit concluded BOP’s categorical categories were too broad and inconsistent (e.g., victims vs. alleged perpetrators treated the same; inconsistent redactions across similar documents) and reversed and remanded for further proceedings and individualized balancing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Exemption 6 justified redaction of names/PII | PLN: BOP’s categorical redactions overbroad; must balance privacy vs public interest case-by-case | BOP: Names/PII in claim forms reveal stigmatizing matters; category-based protection appropriate and supports Exemption 6 | Reversed — BOP’s submissions did not justify categorical redactions; district court must balance interests with better justification |
| Whether a categorical (document-type) Vaughn approach is permissible | PLN: Varied claims (e.g., slip-and-fall vs sexual assault) have different privacy/public interests so categories are improper | BOP: May justify by category when categories sufficiently distinct to show exemption standards met | Categorical approach allowed in principle, but BOP’s categories here were too broad/inconsistent to permit summary judgment; remand required |
| Whether BOP distinguished privacy interests of victims vs alleged perpetrators | PLN: Must differentiate; perpetrator identities often have stronger public-interest justification | BOP: Did not meaningfully distinguish; argued general privacy concerns for all involved | Held: BOP failed to justify lumping victims and alleged perpetrators together; district court gave no weight to distinction; remand instructed to address it |
| Adequacy of Vaughn index and supporting declarations | PLN: Vaughn and Moorer Decl. were cursory and lack reasonable specificity to carry government’s burden | BOP: Vaughn index and Moorer Decl. described document types and asserted privacy/public-interest rationales | Held: Vaughn/decl. were insufficiently specific and inconsistent; government must provide a coherent catalogue and explanation on remand |
Key Cases Cited
- Judicial Watch, Inc. v. Dep’t of Justice, 365 F.3d 1108 (D.C. Cir.) (Exemption 6 privacy analysis framework)
- Horowitz v. Peace Corps, 428 F.3d 271 (D.C. Cir.) (public interest focus: knowing what government is up to)
- Wash. Post Co. v. U.S. Dep’t of Health & Human Servs., 690 F.2d 252 (D.C. Cir.) (Exemption 6 purpose: protect against embarrassment/injury from unnecessary disclosure)
- Citizens for Responsibility & Ethics in Wash. v. U.S. Dep’t of Justice, 746 F.3d 1082 (D.C. Cir.) (permissibility and limits of categorical justifications)
- ACLU v. CIA, 710 F.3d 422 (D.C. Cir.) (categorical withholding where FOIA process would reveal protected information)
- Nation Magazine v. U.S. Customs Serv., 71 F.3d 885 (D.C. Cir.) (categories must characteristically support inference exemption applies)
- Judicial Watch, Inc. v. Food & Drug Admin., 449 F.3d 141 (D.C. Cir.) (Exemption 6 extends to names and addresses)
- Billington v. U.S. Dep’t of Justice, 233 F.3d 581 (D.C. Cir.) (government summary judgment burden in FOIA)
- U.S. Dep’t of Justice v. Reporters Comm. for Freedom of Press, 489 U.S. 749 (U.S. Sup. Ct.) (public interest tied to citizens’ right to know government operations)