## Facts

- The FBI maintains criminal identification records (“rap sheets”) compiling descriptive data and an individual’s arrests, charges, convictions, and incarcerations from multiple jurisdictions.
- A journalist and the Reporters Committee for Freedom of the Press requested, under FOIA, the FBI rap sheet of Charles Medico after allegations linked Medico’s family business to organized-crime influence and improper defense contracting.
- The request was narrowed to rap-sheet entries that reflected matters contained in public records.
- The Department of Justice declined to disclose any rap sheet and would not confirm or deny responsive nonfinancial-crime information.
- The district court, after in camera review, granted summary judgment for the government, holding the rap sheet exempt under FOIA, including Exemption 7(C).
- The D.C. Circuit reversed and remanded, directing a balancing of Medico’s privacy interest against the public interest given that underlying events appeared in public records.

## Issues

1. Whether an FBI rap sheet is a law-enforcement record whose disclosure to a third party can be withheld under FOIA Exemption 7(C) as an unwarranted invasion of personal privacy.
2. Whether the existence of underlying criminal history events in public records negates the privacy interest in a government-compiled rap sheet.
3. What “public interest” counts in Exemption 7(C) balancing—general interest in a private individual’s criminal history or interest in learning about government operations.

## Decision

- The Supreme Court reversed the D.C. Circuit and reinstated judgment for the government.
- The Court held that disclosure of an FBI rap sheet to a third party could reasonably be expected to constitute an unwarranted invasion of personal privacy under Exemption 7(C).
- The Court rejected the view that public-record status of component facts requires disclosure of the compiled rap sheet.
- The Court concluded that the asserted public interest did not outweigh the substantial privacy interest in a centralized criminal-history compilation.
- The Court stated that FOIA provides no special access rights for the press.

## Legal Principles

- Under FOIA Exemption 7(C), law-enforcement records may be withheld when disclosure could reasonably be expected to constitute an unwarranted invasion of personal privacy.
- “Public interest” in Exemption 7(C) balancing is limited to information that sheds light on an agency’s performance of its statutory duties, not information primarily about a private citizen.
- A strong privacy interest exists in government compilation and centralization of criminal-history information, even if individual events are available in dispersed public records (“practical obscurity”).
- FOIA is requester-neutral; the identity or status of the requester (including a news organization) does not expand access rights.
- The compilation character of a rap sheet materially changes the privacy analysis compared to isolated courthouse records.

## Conclusion

The Court held that FOIA Exemption 7(C) allows the government to withhold FBI rap sheets because centralized criminal-history compilations implicate substantial personal privacy interests, and the relevant FOIA public interest is limited to information that reveals how the government performs its duties.


U.S. Dep’t of Just. v. Reps. Comm. for Freedom of the Press, 489 U.S. 749 (1989)