Facts of the Case

CBS requested the criminal identification records of Charles Medico from the FBI. When the FBI refused the request, a CBS news correspondent and the Reporters Committee for Freedom of the Press (RCFP) challenged the denial as a violation of the Freedom of Information Act (FOIA). RCFP claimed that since Medico was an identified organized crime figure with corrupt ties to a United States Congressman, Medico's criminal record was a matter of "public record" and "interest." On appeal from an unfavorable appellate decision, the Supreme Court granted the U.S. Department of Justice certiorari.

Question

Is a refusal to disclose an individual's personal FBI crime record to a third party justifiable under the "personal privacy" invasion exemption of the Freedom of Information Act?

Conclusion

Yes. In a unanimous decision, the Court held that an individual's interest in nondisclosure of any criminal records that the FBI might have on him or her is precisely the sort of "personal privacy" that Congress intended to protect when it enacted FOIA exemptions. Balancing public knowledge interests against privacy considerations, the Court explained that RCFP's request was overly broad. The request sought access to all FBI records on Medico, rather than specific information concerning his file. Moreover, the Court stated that public interest in criminal record information is not increased simply because the requesting party is a news agency.