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**106 ALR, Fed. 94, When Are Government Records ―Similar Files‖ Exempt from Disclosure Under Freedom of Information Act Provision (5 U.S.C.A. § 552(B)(6)) Exempting, Certain Personnel, Medical, and ―Similar‖ Files. **112 ALR, Fed. 561, Exhaustion of Administrative Remedies as Prerequisite to Judicial Action to Compel Disclosure Under Freedom of Information Act (FOIA) (5 U.S.C.A. § 552). **139 ALR, Fed. 225, What Constitutes ―Trade Secrets and Commercial or Financial Information Obtained from Person and Privileged or Confidential,‖ Exempt from Disclosure Under Freedom of Information Act (5 U.S.C.A. § 552(B)(4))... *153 ALR, Fed. 571, What Are ―Records‖ of Agency Which Must be Made Available Under Freedom of Information Act (5 U.S.C.A. § 552(A)(3)). **165 ALR, Fed. 591, What Constitutes ―Agency‖ for Purposes of Freedom of Information Act (5 U.S.C.A. § 552). **169 ALR, Fed. 495, What Matters Are Exempt from Disclosure Under Freedom of Information Act (5 U.S.C.A. § 552(B)(1)) as ―Specifically Authorized Under Criteria Established by an Executive Order to be Kept Secret in the Interest Of... **184 ALR, Fed. 435, Construction and Application of FOIA Exemption 7(F), 5 U.S.C.A. § 552(B)(7)(F), Which Permits Withholding of Information Compiled for Law Enforcement Purposes If Disclosure Could Reasonably be Expected to Endanger Life... **189 ALR, Fed. 1, When Are Government Records Reasonably ―Expected to Interfere With Enforcement Proceedings‖ So as to be Exempt from Disclosure Under Freedom of Information Act Provision (5 U.S.C.A. § 552(B)(7)(A)) Exempting Any... **107 ALR, Fed. 888, Recoupment by Pro Se Litigant of Attorney's Fees Under Equal Access to Justice Act (28 U.S.C.A. § 2412). **104 ALR, Fed. 734, When Are Government Records ―Medical Files‖ Exempt from Disclosure Under Freedom of Information Act Provision (5 U.S.C.A. § 552(B)(6)) Exempting Certain Personnel, ―Medical,‖ and Similar Files. **104 ALR, Fed. 757, When Are Government Records ―Personnel Files‖ Exempt from Disclosure Under Freedom of Information Act Provision (5 U.S.C.A. § 552(B)(6)) Exempting Certain ―Personnel,‖ Medical, and Similar... **82 ALR, Fed. 698, Exhaustion of Administrative Remedies as Prerequisite to Civil Action Under § 3(G) of Privacy Act (5 U.S.C.A. § 552a(G)). **57 ALR, Fed. 903, Use of Freedom of Information Act (5 U.S.C.A. § 552) as Substitute For, or as Means Of, Supplementing Discovery Procedures Available to Litigants in Federal Civil, Criminal, or Administrative... **55 ALR, Fed. 583, What Are ―Enforcement Proceedings‖ Within Freedom of Information Act Exemption from Disclosure of Investigatory Records that Would Interfere With Enforcement Proceedings... **55 ALR, Fed. 903, What Materials Are Exempt from Disclosure Under Privacy Act's Exemption of ―Investigatory Material‖ Contained in 5 U.S.C.A. § 552a(K)(5).
**50 ALR, Fed. 552, When is Federal Agency Justified, Under Freedom of Information Act, in Refusing to Furnish Documents Without Charge or at Reduced Charge for Search and Duplication, Pursuant to 5 U.S.C.A... **5 ALR 6th 327, What Constitutes Commercial or Financial Information, Exclusive of Trade Secrets, Exempt from Disclosure Under State Freedom of Information Acts--General Rules of Construction. **8 ALR 6th 117, What Constitutes Commercial or Financial Information, Exclusive of Trade Secrets, Exempt from Disclosure Under State Freedom of Information Acts--Specific Applications. **26 ALR 4th 666, What Constitutes Personal Matters Exempt from Disclosure by Invasion of Privacy Exemption Under State Freedom of Information Act. **27 ALR 4th 680, What Are ―Records‖ of Agency Which Must be Made Available Under State Freedom of Information Act. **27 ALR 4th 742, What Constitutes an Agency Subject to Application of State Freedom of Information Act. **40 ALR 4th 333, What Constitutes Legitimate Research Justifying Inspection of State or Local Public Records Not Open to Inspection by General Public. **26 ALR 4th 701, Patient's Right to Disclosure of His or Her Own Medical Records Under State Freedom of Information Act. **86 ALR 3rd 571, Right of Defense in Criminal Prosecution to Disclosure of Prosecution Information Regarding Prospective Jurors. **169 ALR 653, Enforceability by Mandamus of Right to Inspect Public Records. **151 ALR 1049, Constitutionality, Construction, and Application of Statutory Provisions Regarding Publicity or Confidential and Privileged Character of Income Tax Information or Returns.
Exemption Application – A public charity must make available for public inspection its exemption application, Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, along with each of the following documents: all documents submitted with Form 1023; all documents the IRS requires the organization to submit in support of its application; and, the exemption ruling letter issued by the IRS. Annual Information Return – A public charity must make available for public inspection its annual information return (Form 990 series) with schedules, attachments, and supporting documents filed with the IRS. However, a public charity that files a Form 990 or Form 990-EZ does not have to disclose the names and addresses of contributors listed on Schedule B. All other information, including the amount of contributions, the description of noncash contributions, and any other information provided will be open to public inspection unless it clearly identifies the contributor.
it should not include its Schedule B in the attachments for the state. **All publicly-available information may be obtained from a fee by using Form 4506-A. A $10.An organization complete copy of its own application by filing Form 4506. A penalty of $20 per day may apply for as long as the failure continues. States that do not require the information might inadvertently make the schedule available for public inspection along with the rest of the Form 990 or Form 990-EZ. see the Life Cycle of a Public Charity and the instructions to Forms 990. 30 http://www.Note: If an organization files a copy of Form 990 or Form 990-EZ. and manner of inperson inspection and copying.This can be done by posting the documents on a readily accessible Web site.gov/Charities-&-Non-Profits/Substantiating-Charitable-Contributions Substantiating Charitable Contributions . 990T and 1023 at www. with any state.gov for interim guidance regarding how the returns are to be made public. no maximum penalty applies to application requests. attachments and supporting documents filed with Form 990-T that do not relate to unrelated business income tax are not required to be made available.**It can charge no more for the copies than the per page rate the IRS charges for providing copies. and may charge a reasonable fee for providing copies.irs. place.irs. Form 990-T– A public charity must make Form 990-T available for the three years beginning on the last day (including extensions) for filing the return.A return must be made available for a period of three years from the date the return is required to be filed or is actually filed.See Announcement 2008-21 for procedures the public may use to request a 501(c)(3) organization's Form 990-T from the IRS. unless a schedule of contributors is specifically required by the state.irs.A tax-exempt organization does not have to comply with individual requests for copies if it makes the documents widely available. whichever is later. Certain information may be withheld from public inspection. the IRS for or Copy of may obtain a Request for PENALTIES Penalties apply to responsible persons of a tax-exempt organization who fail to provide the documents as required. Request for Public Inspection Exempt or Political Organization IRS Form.gov/eo. and attachments. Public Inspection and Disclosure Procedures – A public charity may place reasonable restrictions on the time.000 maximum penalty applies to a failure to provide an information return. Copy of Tax Return.Read Notice 2007-45 and Notice 2008-49 at www. Schedules.For details on disclosure rules and procedures for 501(c)(3) organizations.
If the disclosure statement is furnished in connection with a particular solicitation. 1990-1 C. not to exceed $5. Most eligible organizations are listed in Exempt Organizations Select Check (Pub 78 database). the name of the charity. and Revenue Procedure 92-49. 2. Under a new recordkeeping rule effective for all cash. the donor has made a quid pro quo contribution. credit card charges. there is generally no donative element involved in a visitor's purchase from a museum gift shop). The penalty is $10 per contribution. Even though the part of the payment available for deduction does not exceed $75. a disclosure statement must be filed because the donor's payment (quid pro quo contribution) exceeds $75. 987 (as updated). For example.B. Inform the donor that the amount of the contribution that is deductible for federal income tax purposes is limited to the excess of any money (and the value of any property other than money) contributed by the donor over the value of goods or services provided by the charity. and 2. A charitable organization must provide a written disclosure statement to donors of a quid pro quo contribution in excess of $75.B. There is no donative element involved in a particular transaction with a charity (for example.Many charitable organizations described in section 501(c)(3). No disclosure statement is required when: 1. 471. The charity must furnish the statement in connection with either the solicitation or the receipt of the quid pro quo contribution.000 per fund-raising event or mailing. In this example. They must show the date paid or posted. **Bank records for this recordkeeping requirement include bank or credit union statements. The intangible religious benefit must be provided to the donor by an organization organized exclusively for religious purposes. are eligible to receive tax-deductible contributions in accordance with section 170. the charitable contribution portion of the payment is $60. The charity can avoid the penalty if it can show that the failure was due to reasonable cause. A penalty is imposed on a charity that does not make the required disclosure in connection with a quid pro quo contribution of more than $75. Written records prepared by the donor (such as check registers or personal notations) are no longer sufficient to support charitable contributions. electronic funds transfers. 2006. other than testing for public safety organizations. The required written disclosure statement must: 1. 1992-1 C. There is only an intangible religious benefit provided to the donor. or 3. and the . the donor must obtain and keep a bank record or a written communication from the donee as a record of the contribution. and must be of a type that generally is not sold in a commercial transaction outside the donative context. canceled checks. if a donor gives a charity $100 and receives a concert ticket valued at $40. check. or credit card statements. or other monetary contributions of any amount made in taxable years beginning after August 17. it is not necessary for the organization to provide another statement when the associated contribution is actually received. A quid pro quo contribution is a payment made to a charity by a donor partly as a contribution and partly for goods or services provided to the donor by the charity. Provide the donor with a good faith estimate of the value of the goods or services that the donor received. The goods or services given to a donor meet the standards for insubstantial value set out in Revenue Procedure 90-12.
The contemporaneous written acknowledgment may be contained in the same document as the written communication from the donee used to satisfy the new cash recordkeeping requirement. The donee is not required to record or report this information to the IRS on behalf of a donor.IRS. or a Principal Combined Fund Organization for purposes of the Combined Federal Campaign.online training at StayExempt. as long as it contains all information required by both the recordkeeping requirement and the contemporaneous written acknowledgment requirement. The written acknowledgment must state whether the donee provides any goods or services in consideration for the contribution. An organization described in section 170(c). IRC 6700 and IRC 6701 and Charitable Contribution Deductions Publication 526. For more information. Although there is no prescribed format for the written acknowledgment. For appraisals prepared in connection with returns or submissions filed after August 17. To be contemporaneous the written acknowledgment must generally be obtained by the donor no later than the date the donor files the return for the year the contribution is made. If the donee provides goods or services to the donor in exchange for the contribution (a quid pro quo contribution). Household items and clothing contributed to charity after August 17. A donor claiming a deduction of $250 or more is also required to obtain and keep a contemporaneous written acknowledgment for a charitable contribution . and does not apply to a contribution of an item for which a deduction of more than $500 is claimed if the taxpayer obtains a qualified appraisal of the item. 2006.gov Contributions of vehicles Page Last Reviewed or Updated: 28-Jan-2014 DISCLOSURE REQUIREMENTS REGARDING FINANCIAL DOCUMENTS THAT MUST BE PROVIDED TO A MEMBER OF THE PUBLIC UPON REQUEST . it must provide sufficient information to substantiate the amount of the contribution. and (2) a pledge card other document prepared by or at the direction of the charity that shows the name of a donee. or other document furnished by the employer that states the amount withheld for payment to charity. The donor is responsible for requesting and obtaining the written acknowledgement from the donee. the written acknowledgment must include a good faith estimate of the value of the goods or services. other art objects.000. Additional information Publication 1771. will be treated as a donee organization for purposes of the new recordkeeping provision. Charitable Contributions Required Disclosures . jewelry and gems. Taxpayers who claim charitable contributions made by payroll deduction can satisfy the recordkeeping requirement if the donor has (1) a pay stub.Substantiation and Disclosure Requirements Updates on Disclosure and Substantiation Rules. see Notice 2006-96. W-2. antiques. This requirement does not apply to contributions of food. 2006 must be in at least good used condition to be deductible. or collections.amount of the payment. generally a qualified appraisal prepared by a qualified appraiser must be obtained. Charitable Contributions . For claimed contributions over $5. see Publication 1771. paintings.
A tax-exempt organization must keep documentation that supports entries in the books. for the preceding three years. ı You MAY NOT require the person making the request to tell you the reason they want to see the materials. it should ensure that the records appropriately identify the income and expense items that are attributable to each program. employment taxes. expenses (other than purchases).15 for each additional page of copying. http://www. purchases. with all materials submitted in support of the application. A tax-exempt organization can choose any recordkeeping system. upon request during normal business hours. or any IRS letters issued in response to your annual tax return. ı The annual federal tax return. The types of activities a tax-exempt organization conducts determines the type of records that should be kept for federal tax purposes.00 for the first page and $0.Federal tax documents must be available for inspection by the public -. If a tax-exempt organization has more than one program. ı The IRS‘s determination letter issued in response to your application for tax exempt status. While there is a limited exception to the requirement that you have the materials available at regional and branch offices.pgdc. and the form 990-T. at your principal office and any regional or district office with three or more full-time employees (or the part-time equivalent). Consult your state’s charity regulatory authority for more information. form 990.com/pgdc/irs-releases-compliance-guide-tax-exempt-organizations-other501c3-public-charities-and-private-foundations What records should be kept? Except in a few cases. the law does not require a special kind of record. ı The original application for tax exempt status. When providing public access to these federal tax documents: ı Documents must be provided free of charge. Some states also have public disclosure requirements for nonprofits’ financial documents. For most small organizations. the checkbook might be the main source for entries in the books while larger organizations would need more sophisticated ledgers and records. 2006). that clearly shows the organization's income and expenses. suited to its activities. and assets. schedules. (deposits). except you may omit: lists of names and addresses of contributors. The Taxpayer‘s Bill of Rights enacted in 1996. accounting journals and ledgers). You MAY charge $1. except that you may charge a reasonable fee for reproduction and mailing costs. The books must show gross receipts. A recordkeeping system should generally include a summary of transactions. the Exempt Organization Business Income Tax Return (for form 990-Ts filed after August 17.The following federal tax documents should be available for inspection. also requires that you honor in-person or written requests for copies of these documents. we recommend you have the materials available at any site with three or more full-time equivalent employees. form 1023 or 1024. This summary is ordinarily written in the tax-exempt organization's books (for example. A tax-exempt organization should set up a recordkeeping system using an accounting method that is appropriate for proper monitoring and reporting of its financial activities for the tax year. **The copy available for public inspection should include all attachments. Accounting Periods and Methods .
There are two basic accounting methods: cash method Under the cash method. **purchases. sales. **paid bills. Under an accrual method. This is a period of 12 consecutive months ending on the last day of any month except December. It is important to keep these documents because they support the entries in books and the entries on tax and information returns.e.Tax-exempt organizations must keep their financial records based on an annual accounting period. Accounting Periods -. a tax-exempt organization reports income in the tax year received. in the tax year in which a pledge is received.A tax year is usually 12 consecutive months. see Publication 538.contain information to be recorded in accounting records. There are two kinds of tax years. receipts. called a tax year. a tax-exempt organization generally records income in the tax year earned (i.. Records Management **GROSS RECEIPTS . whether or not it pays the expenses that year. invoices. It records expenses in the tax year incurred. accrual method For more information about accounting periods and methods. fiscal tax year Accounting Method -. deposit slips. and the instructions to Form 990 and Form 990-EZ. Accounting Periods and Methods. and **canceled checks -. Also. A tax-exempt organization chooses an accounting method when it files its first annual return. Tax-exempt organizations should keep supporting documents organized by year and type of receipt or expense. sales slips. These documents -. Supporting Documents Organization transactions such as contributions. calendar tax year This is a period of 12 consecutive months beginning January 1 and ending December 31. and **payroll will generate supporting documents. keep records in a safe place. in order to comply with annual reporting requirements.grant applications and awards. It usually deducts expenses in the year paid. even though it may receive payment in a later year).An accounting method is a set of rules used to determine when income and expenses are reported.
**bank deposit slips.Gross receipts are the amounts received from all sources. loans or other forms of debt. **EXPENSES Expenses are the costs a tax-exempt organization incurs (other than purchases) to carry on its program. and furniture) an organization owns and uses in its activities. notes. documents that show gross receipts include: donor correspondence. Supporting documents should show the amount paid. and invoices. Thus. cost of any improvements. it must account for any items resold to customers. Information related to independent contractors should also be maintained. cash register tape receipts. pledge documents. for general information on methods for valuing inventory. for example. if any. deductions taken for depreciation. and **petty-cash slips for small cash payments. invoices. buildings. **credit card sales slips. documents for expenses include: **canceled checks. **account statements. including contributions. EMPLOYMENT TAX RECORDS Organizations that have employees must keep records of compensation and specific employment tax records. Supporting documents should show the amount paid and the purpose of the expense. invoices. liabilities reflect the financial obligations of the organization. Circular E. cash register tapes. Miscellaneous Income. contracts. See Publication 15. for details. cash register tapes. **PURCHASES. receipt books. See Publication 538. INCLUDING ACCOUNTING FOR INVENTORY Purchases are items bought. If a taxexempt organization produces items. . These records will help an organization determine the value of its inventory at the end of the year. Employer's Tax Guide. Records should show: when and how the asset was acquired. a tax-exempt organization should keep supporting documents that show the amounts and sources of its gross receipts. including any items resold to customers. documents for purchases include: **canceled checks. **credit card charge slips. purchase price. Accounting Periods and Methods. the organization must account for the cost of all raw materials or parts purchased for manufacture into finished products. ASSETS & LIABILITIES Assets are the property. whether any debt was used to acquire the asset. how the asset was used. such as losses resulting from fires or storms. and Forms 1099-MISC. documents relating to mortgages. **credit card sales slips. if any. a tax-exempt organization must keep records to verify certain information about its assets and liabilities. deductions taken for casualty losses. (such as investments. and that the amount was for purchases.
These include account statements prepared for the financial institution by a third party. including state or local tax purposes. all information. real estate closing statements.Some records should be kept permanently. payee's name. when and how the asset was disposed of. ________________________________________________________________ **credit card amount charged. funds transfer and date the transfer was posted to the account by the financial institution. and date the check amount was posted to the account by the financial institution.If an organization has employees. it may be able to show payment with certain financial account statements prepared by financial institutions. the statute of limitations runs three years after the date the return is due or filed. amount. Generally. including account statements must be legible. payee's name. and financing documents. An organization may be required to retain records longer for other legal purposes. **canceled checks. and transaction date. expenses of sale. Permanent Records -. Record Retention Periods Record retention periods vary depending on the types of records and returns. Generally. whichever is later. Documents that may show the above information include: **purchase and sales invoices. selling price. as well as board minutes. it must keep employment tax records for at least four years after the date the tax becomes due or is paid. whichever is later. IF payment is by: THEN statement must show: ________________________________________________________________ **check check number. Employment Tax Records -. These include the application for recognition of tax-exempt status. How long should records be kept? Tax-exempt organizations must keep records for federal tax purposes for as long as they may be needed to document evidence of compliance with provisions of the Code. the determination letter recognizing tax-exempt status. ________________________________________________________________ **electronic amount transferred. . this means the organization must keep records that support an item of income or deduction on a return until the statute of limitations for that return runs. The following defines acceptable account statements. such as articles of incorporation and bylaws. with amendments. The statute of limitations has run when the organization can no longer amend its return and the IRS can no longer assess additional tax. and organizing documents. payee's name. If a tax-exempt organization does not have canceled checks.
a grantor. **Disclosure of gross salaries of all city employees who earned at least $100. Cir.C. (CCH) ¶11510 (D.000 to newspaper that sought information did not constitute "unwarranted invasion of privacy" within meaning of exemption from disclosure in California Public Records Act (CPRA). and local governments including this city until it had recently passed ordinance to contrary. Teamsters Local 856 v. by other means. West's Ann. 5 Cal. Priceless. Rptr. of Housing and Urban Development. . it was held or otherwise recognized that such records were public records within the meaning of statutes or constitutional provisions authorizing access to public records. International Broth. creditor. 112 Cal. and it accordingly was held in a number of cases that the records were subject to disclosure to the public. if at all. disclosure was warranted where revealing employee's wages for only one job would not be embarassing. prime function of Act was to enable public to survey operations of its government. 2003).2d 435. Cal. 1985). App. 201 Cal Rptr 654. or state agency may require that records be kept longer than the IRS requires. public's interest in assuring that anti-kickback and prevailing-wage laws were being enforced outweighed any embarassment to employees from disclosure of their non-union status. **In action by union under Freedom of Information Act to compel disclosure of names of eight employees listed on certified payroll reports submitted to federal government by non-union contractor in connection with one construction job. § 3[a] Payroll records as public records—Held to be public records [Cumulative Supplement] In the circumstances of the following cases involving questions as to public disclosure of payroll or salary records of individual government employees. insurance company.Records for Non-Tax Purposes -.S. state. 3d 847 (1st Dist. an organization should keep them until they are no longer needed for non-tax purposes. LLC. of Elec.When records are no longer needed for tax purposes. and it did not appear that union could have obtained desired information readily. 4th 1500. 103 Lab. disclosure of salary information had been longstanding practice of federal. **See Braun v City of Taft (1984. § 5. Cas. Local 41 v. 5th Dist) 154 Cal App 3d 332. release of other detailed information concerning the payment of employees. for purpose of determining propriety of preliminary injunction prohibiting disclosure of detailed salary information in action brought by newspaper against cities under California Public Records Act (CPRA). evidence supporting nondisclosure included city policy manuals and union agreements indicating salary data was confidential. 763 F. employees' reasonable expectations of privacy. For example. Dept. Gov. Code §§ 6250 et seq. U. and lack of evidence suggesting release of the employees' names and their compensation would advance public interest in efficient governmental operations. Workers. § 3[b] Payroll records as public records—Held not to be public records Public employees' privacy interest in nondisclosure of individually identifiable salaries outweighed public interest in disclosure.
**In action brought by city councilman. 14 A.Code §§ 6254(c). App.C. even though information on salary card had been of personal nature and there had been chance of invasion of privacy. 654 (5th Dist. § 1. In News Group Boston. under the Public Records Act does not California Constitution. Cas. § 552) (FOIA). West's Ann. AFL-CIO v.Cal. payroll information concerning Amtrak employees was found not to be exempt from disclosure under FOIA.R. 195 Cal. 4th 319. where city had not shown that public interest in nondisclosure had clearly outweighed public interest served by disclosure. Superior Court. showing firefighter's salary along with other personal information. for writ of mandate to set aside censure action. trial court properly found that salary card had been public record and had not been confidential personnel record. 20 Media L R 1816. had been clearly related to conduct of city's business and thus had been public record.S.R. **The disclosure of public salary information violate the right of privacy protected by the Const.and disclosing such information furthered strong public interest in knowing how government money was spent. where state statute exempting personnel records from disclosure to public in situations where disclosure would constitute unwarranted invasion of personal privacy had not applied.C. Sacramento County Employees' App. City of Taft. trial court had carefully considered clash between need for public disclosure of its business and need by individual for privacy in determining that there had been no invasion of privacy.A. 64 Cal. The courts in the following cases have held that this type of information is not exempt from disclosure under exemption 4 (5 U. 3d 332. inasmuch as. **Right of privacy. 1984). Rptr. v National R. 2011). 57 A. and where.A. 6250 et seq. Passenger Corp. § 552(b)(4)) (FOIA) § 22[a] Personnel information—Subject to disclosure [Cumulative Supplement] Affirmative action plans. where salary card.A. who had been censured for release of salary card of city firefighter to member of press. 35 Media L.Code § Retirement System v." Exempt From Disclosure Under Freedom of Information Act (5 U. 2011 WL 1797199 (3d Dist.3d 16 . West's Ann.R. 26 I.S. in balancing constitutional right to privacy against public's interest in city's business. despite Amtrak's argument that disclosure of its labor costs might threaten its overall productivity and ability to compete in the marketplace.Gov. Braun v. 42 Cal. equal employment reports and other information relating to personnel and payroll matters submitted to government agencies by contractors and others have been the subject of disclosure requests under the Freedom of Information Act (5 U.C.3d 488. 201 Cal.E. Rep. data listed on card had not been in any way embarrassing and salary classification had been public information. 139 alr fed 229 What Constitutes "Trade Secrets and Commercial or Financial Information Obtained From Person and Privileged or Confidential. § 552(b)(4)).L. 154 Cal. DC Mass) 799 F Supp 1264. 1. Inc. (BNA) 940.S.L.Cal. 3d 693. Superior Court.2d 750 **Waiver or loss of right of privacy. (1992. West's Ann.Cal. Art. 6255(a). Local 21. The court found no specific factual or evidentiary proof to support Amtrak's claim.Gov. Rptr. (BNA) 2590 (2007). 165 P. International Federation of Professional and Technical Engineers. 4th 440.
or condition reports prepared by.) 2005. and thus. 246 U. **bank records. personnel. 631 F.C.2d 435. Unreported. C. Federal Deposit Ins.D. Tomscha v. or for use of an agency responsible for regulation or supervision of financial institutions will not prevent disclosure of closed bank records ―for centuries‖ contrary to policy of encouraging reasonable full disclosure of governmental activities inasmuch as agency is free to release records and its discretion in respect thereto is exercised pursuant to published regulations. operating. Workers Local 41 v.C.s. social security numbers and phone numbers of individuals mentioned in securities transaction reports. affirmed 763 F.C. Securities and Exchange Commission.App.Securities and Exchange Commission personnel. records compiled for law enforcement purposes Of the names.C.1980. 501 F. Corp. since.Supp. Wage and pay information.S. D.. Records 60 1209.1980. v.2d 896. of Housing and Urban Development.5 u.App. 203 U. Freedom of Information Act (FOIA) exemption for personnel records was applicable to FOIA request brought by employee of the General Services Administration (GSA) who sought information regarding why coemployee at the GSA was given certain awards and financial bonuses. plaintiff was entitled only to release of names of Commission employees. Ltd. 898.. 158 Fed. exemptions generally Literal application of statutory exemption against disclosure afforded matters contained in or related to examination. 552 561. 542. regulation or supervision of. International Broth. Records 58 **The release of the justifications for co-employee's awards would constitute more than a de minimis invasion of privacy. there was legitimate public interest in knowing who at the Commission conducted an investigation so those individuals could be subject to inquiry.S. General Services Admin. co-employee's interest in keeping personal information regarding his job performance private outweighed any interest the public might have in disclosure of such information.C.A.D.C. invasion of privacy. Records 58 330.Appx. 314. Financial records . C. Gregory v. Canadian Javelin.S. 329.2 (N. U.D. financial institutions. as they necessarily included personal. 145. of Elec.D. D.D. on behalf of. 593 F.1984. medical and similar files causing invasion of personal privacy **Disclosure of wages from a particular job would not disclose or give key to a disclosure of a person's entire income to extent that disclosure would be so embarrassing as to warrant application of exemption from disclosure for personnel and medical files under subsec. (b)(6) of this section disclosure of which would constitute clearly unwarranted invasion of personal privacy. as to that information. addresses. ---. information regarding his job performance.Supp. lists of subscribers.Y. ---.A. Securities and Exchange Commission memos and other records withheld by Commission pursuant to investigatory records/personal privacy exemption.C. albeit positive. 2005 WL 3406575. Dept.Mandatory nature of exemptions. Records 54 1384.c.
S.A. where document is properly classified "confidential" pursuant to Executive Order No. American Jewish Congress v Department of Treasury (1982.A.. See priv_commun_confid_other_priv_bank_&_customer_bank_records_fed_all_digest. . SEC failed to provide any support for its overly generous interpretation of "personal financial information. moreover. the financial records of any customer except in accordance with the provisions of this chapter." and thus. employees. Chemical Bank. §§ 3401 et seq. .**Document containing most recent aggregate figures showing amount of deposits in United States banks by foreign persons from 3 Arab countries and amount of Treasury bills owned or held by such persons is protected from disclosure in action under Freedom of Information Act by Exemption 1 (5 USCS § 552(b)(1)). not access in litigation between two private parties.) **Sneirson v. cert den (1983) 464 US 895. 1110. 109 A. Financial records or information **There was no indication that requested e-mails contained information about either of authors' personal finances.S.L. affd without op (1983. 5 USCS § 552. 12 U.1985 Privilege against bank's disclosure of customer's financial records in bank's custody was not established by reference to Right to Financial Privacy Act.Del..9. Exemption 7(C). (b) Release of records upon certification of compliance with chapter . 108 F. 3410 . §§ 1101 et seq.C.A. Right to Financial Privacy Act of 1978. court found that communications between them were not protected by Freedom of Information Act (FOIA). Fed. App DC) 230 US App DC 70.D. 730. 12065 and affidavits of Treasury Department officials show harm to national security that could reasonably result from disclosure. Confidentiality of financial records (a) Release of records by financial institutions prohibited No financial institution. 159 D.2d 316 C. **112 ALR. DC Dist Col) 551 F Supp 2d 33. DC Dist Col) 549 F Supp 1270.1969 **Communications between bank and depositor are not privileged. 78 L Ed 2d 233. Construction and Application of Right to Financial Privacy Act of 1978 (12 U.).R. 413 F.S.C. 713 F2d 864. §§ 3401 et seq. Aguirre v SEC (2008. especially in view of expressed desire of foreign governments involved to keep information held in confidence. § 3403. 295. 1450 (1937) HN: 2.5 (F. may provide to any Government authority access to or copies of. or agent of a financial institution. or officer.doc [Cited 19 times for this legal issue] Harris v.A.C.D.R. which limits government access to individual financial records. § 3401 et seq.. [Cited 3 times for this legal issue] 12 U. or the information contained in.R. as would be found in bank statements or tax returns and one's financial interest in other's firm did not lead to protection for their business discussions. 12 U..C.Cal. 104 S Ct 244.S. **29 Testimonial or evidentiary privilege in respect of business transactions between banker or broker and customer.S. U.
Ct.Ct.2d 71. or loan insurance agreement. 304. 425 U. law. 19 L. 1642. as an incident to processing an application for assistance to a customer in the form of a Government loan. loan guaranty.Ed. v. 790 (1967). from notifying a Government authority that such institution. 48 L.Ed.2d 576. . (1) Nothing in this chapter shall preclude a financial institution. or as an incident to processing a default on. employee. 87 S. loan guarantee. or agent of a financial institution. or processing an application with regard to a Government loan. collecting a debt. law. proving a claim in bankruptcy. Miller.1995. or agent has information which may be relevant to a possible violation of any statute or regulation. (2) Nothing in this chapter shall preclude a financial institution. (d) Release of records as incident to perfection of security interest. Apr 21. 507. S.Colo. Any financial institution. Miller that bank customer has no constitutionally protected privacy interests in bank records.‖ But in Katz the Court also stressed that ―(w)hat a person .2d 782. corporation. loan guaranty. He relies on this Court's statement in Katz v. or account involved in and the nature of any suspected illegal activity.Supp. or administering. employee. Purpose Right to Financial Privacy Act (RFPA) was passed by Congress in order to provide protection against unrestricted access to financial records to fill in void left by Supreme Court's holding in United States v. or regulation of any State or political subdivision thereof to the contrary. as an incident to perfecting a security interest. Banks And Banking 151 U. or officer.S. 1976) Respondent urges that he has a Fourth Amendment interest in the records kept by the banks because they are merely copies of personal records that were made available to the banks for a limited purpose and in which he has a reasonable expectation of privacy.‘ ‖ and that a ―search and seizure‖ become unreasonable when the Government's activities violate ―the privacy upon which (a person) justifiably relie(s). 88 S.. etc. or officer. from initiating contact with an appropriate Government authority for the purpose of providing any financial record necessary to permit such authority to carry out its responsibilities under a loan. quoting Warden v. shall not be liable to the customer under any law or regulation of the United States or any constitution. 387 U. 96 S. Hayden. 294. or regulation of any State or political subdivision thereof. 442. from providing copies of any financial record to any court or Government authority. or any officer. 435.S. proving a claim in bankruptcy. (c) Notification to Government authority of existence of relevant information in records Nothing in this chapter shall preclude any financial institution. or loan insurance agreement. D. (U. that ―we have .Ed. departed from the narrow view‖ that ― ‗property interests control the right of the Government to search and seize.Ga.S. 1648. 353. 347.S. employee.A financial institution shall not release the financial records of a customer until the Government authority seeking such records certifies in writing to the financial institution that it has complied with the applicable provisions of this chapter. Widnall. McDonough v. . 1. 389 U. a Government guaranteed or insured loan. for such disclosure or for any failure to notify the customer of such disclosure. making a disclosure of information pursuant to this subsection. 1619. 1439. or agent thereof. 583 (1967). 891 F. or otherwise collecting on a debt owing either to the financial institution itself or in its role as a fiduciary. United States. Such information may include only the name or other identifying information concerning any individual.Ct. 18 L. Such information may be disclosed notwithstanding any constitution. 512.
Cf.S.S. in revealing his affairs to another. The lack of any legitimate expectation of privacy concerning the information kept in bank records was assumed by Congress in enacting the Bank Secrecy Act. This analysis is not changed by the mandate of the Bank Secrecy Act that records of depositors' transactions be maintained by banks.Ct. United States..2d.S.Ed. This Court has held repeatedly that the Fourth Amendment does not prohibit the obtaining of information revealed to a third party and conveyed by him to Government authorities. at 511. . . 17 L. 507. 323. 389 U. 93 S. The checks are not confidential communications but negotiable instruments to be used in commercial transactions. supra.Ct. at 51-53. at 382. 347. 1976). 48 L. 351. Couch v. 424. contain only . 385 U.Ed.Ed. Lopez v.2d 576.. 373 U. 96 S. are acting solely as agents of the Government.Ed. including financial statements and deposit slips. 88 S. 94 S. stated. s 1829b(a)(1).Ct.. 1122. In California Bankers Assn.S. **we perceive no legitimate ―expectation of privacy‖ in their contents.S. 28 L. 335.  Even if we direct our attention to the original checks and deposit slips. including financial statements and deposit slips. 751752. All of the documents obtained. 401 U.Ct. 87 S. 39 L.Ed. and regulatory investigations and proceedings. Miller. 435. at 459. United States. United States. United States.. at 403-405. 1381.Ed. there would be no intrusion upon the depositors' Fourth Amendment rights. v. Shultz.Ct. 583 (1967).Ga. we rejected the contention that banks. .S. at 302.2d 462 (1963). S. 458-459 (1971).2d 312 (1966)...2d.Ct.S. is not a subject of Fourth Amendment protection. 87 S. White. at 835-836.2d. 409 U.  The depositor takes the risk.‖ 12 U. such as that protecting communications between an attorney and his client. 91 S.‖ And the court stated. 17 L. 93 S.2d 71. rather **1624 than to the microfilm copies actually viewed and obtained by means of the subpoena. Cf. v. 34 L. 34 L. 745.. **we perceive no legitimate ―expectation of privacy‖ in their contents. 442. the expressed purpose of which is to require records *443 to be maintained because they ―have a high degree of usefulness in criminal tax. Hoffa v.Ct. 558.knowingly exposes to the public . at 582. 28 L. at 752. Lewis v.Ed. 322.Ed.S.. at 52-53. 416 U. Fisher v. at 619. Id. 1619. at 351. United States. at 558. 425 U. (U. 48 L. that the information will be conveyed by that person to the Government.Ct. 96 S.Ct. 385 U.S.S. United States. We do not address here the question of evidentiary privileges. if we direct our attention to the original checks and deposit slips.‖ 389 U.C.Ed. ―(w)hat a person knowingly exposes to the public . Couch v. even if the banks could be said to have been acting solely as Government agents in transcribing the necessary information and complying without protest FN5 with the requirements of the subpoenas. contain only information voluntarily conveyed to the banks and exposed to their employees in the ordinary course of business.Ed. 206. 611. at 413.Ct.Ed. But. 427. Apr 21. 429. The checks are not confidential communications but negotiable instruments to be used in commercial transactions. 88 S. 1125-1126. 10 L. 91 S. United States. at 1577. at 335.S. See Osborn v.. is not a subject of Fourth Amendment protection. In the U. even if the information is revealed on the assumption that it will be used only for a limited purpose and the confidence placed in the third party will not be betrayed.Ct. 17 L.2d 548. We must examine the nature of the particular documents sought to be protected in order to determine whether there is a legitimate ―expectation of privacy‖ concerning their contents.2d. 19 L. United States v. 83 S.Ed. when keeping records of their depositors' transactions pursuant to the Act. Cf.Ct.2d. 385 U.. 619 (1973). United States. 87 S.Ct. the court citing. 425 U. 512. at 1512-1513.S. Katz v. .Ed. All of the documents obtained.. rather **1624 than to the microfilm copies actually viewed and obtained by means of the subpoena. at 1126.2d 453.S.2d. 19 L.2d 394 (1966).FN4 FN4.
2010 Information sought in bank's subpoena. § 3404. and regulatory investigations and proceedings. 745. 34 L. should not have been dismissed pursuant to rule precluding accrual of § 1983 claim when successful claim would necessarily imply invalidity of conviction in pending criminal prosecution.C. White.S.Ct. at 619. 91 S.FN4 (U.. The lack of any legitimate expectation of privacy concerning the information kept in bank records was assumed by Congress in enacting the Bank Secrecy Act. James. 28 L. § 1983. and therefore LLC's motion to compel was granted in LLC's negligence action against bank. 1381. supra. 42 U. Lopez v. subpoena seeking a party's bank records may not be quashed on this basis. **U. 87 S.Ct. 260 Fed.Supp.C.Ed.2d 462 (1963). at 558. borrower had no legitimate expectation of privacy in financial banking records.Ct.2d. While a Pennsylvania court had previously recognized a duty on a bank to keep customer's bank account information confidential as an implied contractual duty. as long as it was [Cited 0 times for this legal issue] .T. Ass'n v. Pa. 91 S.2001 Privacy protection under the Gramm-Leach-Bliley Act exists even where the information is otherwise publicly available: the information is still protected.S. the request for bank records was a formal request for discovery made pursuant to LLC's litigation. United States. 17 D. 435.S. 1122. 751-752. 93 S. United States v.. v. for information on ―all accounts owned in whole or in part‖ by borrower was not privileged.1 311Hk4072019438361001012019438361001 [Cited 0 times for this legal issue] **Individual Reference Services Group.Ed. 2007).S. which were not brought under § 1983. United States. v..A. 1125-1126.‖ 12 U.Ct. 10 L.D. 83 S. 442-443) **State prisoner's Fair Credit Reporting Act and state and federal Right to Financial Privacy Act claims arising out of ongoing prosecution in state court.2d 453. the expressed purpose of which is to require records *443 to be maintained because they ―have a high degree of usefulness in criminal tax. Young v..2010 Since a customer's bank records lack any legitimate expectation of privacy. 17 D. Miller.Ed..S. supra. 458-459 (1971).S.Ed. at 302.  The depositor takes the risk..2d 6 D. in revealing his affairs to another.D.2d. 427. 385 U. at 752. as required for borrower to quash subpoena in mortgage foreclosure action.Pa. Hoffa v.Niester v. 425 U. F. 1 (9th Cir. at 459. 28 L. that the information will be conveyed by that person to the Government. Appx.D. s 1829b(a)(1). Bank Nat.S.S.C. at 413.Ct.2d. Cf. Id. 145 F. 2009 WL 2179356 West KeySummary E. even if the information is revealed on the assumption that it will be used only for a limited purpose and the confidence placed in the third party will not be betrayed. 17 L. Couch v.S. Ass'n v. 373 U. 401 U. at 1126.. United States. [Cited 0 times for this legal issue] **U. Inc...C.Ed.information voluntarily conveyed to the banks and exposed to their employees in the ordinary course of business. Moore. LLC alleged the bank was negligent for allowing the creation of an account without doing due diligence for accepting the deposited checks. at 382.C.Me.Me.R. 264 F. James. Trans Union. 264 F.2009Discovery information requested by limited liability corporation (LLC) related to bank accounts were not impliedly confidential.S. This Court has held repeatedly that the Fourth Amendment does not prohibit the obtaining of information revealed to a third party and conveyed by him to Government authorities. Bank Nat.R.D. at 335.
A private organization is not an agency even if it is performing work under contract with the Government or is receiving Federal financial assistance.C. Criminal Court. **361 What Constitutes "Agency" for Purposes of Freedom of Information Act (5 U. 6801 to 6809. 15 U. Korea.Idaho.2d 720 C. hence. Payroll Records of Individual Government Employees as Subject to Disclosure to Public. we consider records of individual beneficiaries located in the State Disability Determination Services (DDS) to be agency records.Cal. secs. Solely for the purpose of disclosure under the FOIA. CFR §402. What Constitutes an Agency Subject to Application of State Freedom of Information Act. **100 ALR 3rd 699.. 555 F.S.2d) **In re Request For Judicial Assistance from Seoul Dist. Const_law_right_to_privaccy_partic_issues_applic_public_employees_&_officials_financial_ information_ca_all_digest. military department.C.14. **40 ALR 4th 333. as recognized under California Constitution.S. § 6809(4)(C)(i) . § 1782 . 165 A.S. Inc.12. Grantee and contractor records are not subject to the FOIA unless they are in the possession or under the control of SSA or its agents. affords limited protection to bank customer information.2009 City employee lacked reasonable expectation of privacy in bad checks that she issued and placed in stream of commerce. or other establishment in the executive branch of the Federal Government. Gramm-Leach-Bliley Act. Action Collection Service.2d) .30 Definitions. Fed.A. What Constitutes Legitimate Research Justifying Inspection of State or Local Public Records Not Open to Inspection by General Public. since checks were not confidential communications but negotiable instruments to be used in commercial transactions and contained information voluntarily conveyed to third parties.doc [Cited 3 times for this legal issue] **Mangum v.L.3d 935 C.15 (F.7.L. and Application of Information Privacy Provisions of Gramm-Leach-Bliley Act.R..A.9.C. [Cited 1 times for this legal issue] **27 ALR 4th 742. government controlled corporation. 28 U. Fed.1977 Right of privacy.A. Seoul.A. s552). 5 A. no state law privilege precluded compelled production of the records in response to request by foreign tribunal for assistance in procuring the records in connection with investigation of foreign citizen for violating currency laws. in that the bank is to be deemed to have agreed not to divulge such information absent court order. 575 F. As used in this part.R. or any independent regulatory agency. Agency means any executive department.A.C. thereby precluding her claim against city for deprivation of her right to privacy or right to informational privacy by obtaining copies of her bad checks from debt collector.Supp.S. 2d 497 (2005) HN: 2 (F. government corporation.9. Construction. § 509(4)(C)(i). and Regulations Promulgated Thereunder.derived using nonpublic personal information. 591 (2000) HN: 1.A. 15 U. 48 Validity.
R. 34 A.Const.4th 959 (1980) 70 A. Amends.R.T. and that bank did not have right to assert that compliance with summons constituted an infringement upon right of privacy of persons named as payees on checks drawn on account or as drawers on checks payable to account. The Court of Appeals. granted the Service's motion for summary judgment.S. West Headnotes  Constitutional Law 92 4149 92 Constitutional Law 92XXVII Due Process 92XXVII(G) Particular Issues and Applications 92XXVII(G)6 Taxation 92k4149 k. and effect of state laws requiring public officials to protect confidentiality of income tax returns or information. construction.S.S.C. § 552). 57 A.S.A. where none of cost of examination of records would be attributable to efforts not essential to service's investigation of bank customers.L. 74-2 USTC P 9686 (10th Cir.A. Federal Taxes. 68 A. 7603. 1974) Petition by Internal Revenue Service for judicial enforcement of summons demanding that bank produce for examination records reflecting deposits to account of named bank customers and cancelled checks drawn on account. Affirmed..S. held that compliance with summons would not impose unreasonable financial burden on bank in light of Service's offer to provide personnel and equipment required to locate and copy requested records. 70 A.A. Lewis. 503 F.2d 45.C.L. bank was asked only to provide use of records identified specifically by customers' names and account numbers. Most Cited Cases (Formerly 92k286) Compliance with summons issued by Internal Revenue Service and seeking from bank records reflecting deposits to the accounts of named customers for a two-year period and cancelled checks drawn on customers' accounts for two-year period did not impose an unreasonable financial burden on bank so as to result in an unconstitutional taking under the Fifth Amendment.C.R. Willis W. (I. 552). 1 A.L. Chief Judge. U. 842 **Meaning of term "agency" for purposes of Freedom of Information Act (5 U. Fed. .L.**What is "agency" within meaning of Federal Sunshine Act (5 U. 2d 240 Discovery and inspection of income tax returns in actions between private individuals U. Ritter.R. The United States District Court for the District of Utah.2d 240 (1960) 3 Validity. J. Service offered to provide personnel and equipment required to locate and copy needed records and bank would in fact incur only a minimal financial burden. S. § 552b). Continental Bank & Trust Co.1954) §§ 7602.L. 4.2d 74-5831.C. 5.R.(Utah). v.L. sec. 561 (1993) *4 Discovery and inspection of income tax returns in actions between private individuals.R. 112 A. Fed. Fed. 295 Exhaustion of administrative remedies as prerequisite to judicial action to compel disclosure under Freedom of Information Act (FOIA) (5 U.R.A.A.F. Internal Revenue. 26 U. Sep 10.R.C. and the bank appealed.C..
S. at 360-361. **the FOIA's central purpose is to ensure that the Government's activities be opened to the sharp eye of public scrutiny And the court stated at p.S. at 1604. 772. Reporters Committee For Freedom of Press. U.R.1954) §§ 7402(b).‘ ‖ Department of Air Force v.C. Rose. at 1599 (quoting S. 773. Banks and Bank Records. 9 J. 7604(a).C.A. 109 S. 775. This basic policy of ― ‗full agency disclosure unless information is exempted under clearly delineated statutory language. And the court stated at p.. **we note that **Congress has provided that the standard fees for production of documents under the FOIA shall be waived or reduced ―if disclosure of the information is in the public interest because it is likely to contribute significantly to public understanding of the operations or activities of the government and is not primarily in .Rep.. 26 U.Rules Civ. 489 U. 1468.2d 774 ―the basic purpose of the Freedom of Information Act ‗to open agency action to the light of public scrutiny. 733 (1980) (―The act's first and most obvious goal (reflected in its basic disclosure requirements) is to promote honesty and reduce waste in government by exposing official conduct to public scrutiny‖). 425 U. 425 U.Ct. And the court stated at p. 1st Sess.S. 96 S. Most Cited Cases (Formerly 220k1460) Privileged Communications and Confidentiality 311H 407 311H Privileged Communications and Confidentiality 311HVII Other Privileges 311Hk407 k. thus. 96 S. 7603. Internal Revenue 220 4500 220 Internal Revenue 220XX Examination of Persons and Records 220k4500 k. 749. Most Cited Cases (Formerly 220k1460) Individuals who were named either as payees on checks written by bank customers or as drawers on checks payable to bank customers and bank customers could assert no proprietary interest or bank depositor privilege in bank's records reflecting deposits to customers' accounts and cancelled checks drawn on accounts. Rose.‘ ‖ Department of Air Force v.Proc. 774. 28 U.S. And the court stated at p. 772. Fed. Dept.Ct. No.C.Ct..Ed. at 372.S.. Bank Records.S. 103 L.A. 3 (1965)). such individuals and customers could not intervene in proceeding to enforce summons issued by Internal Revenue Service and seeking such records from bank. 7602.‖ Official information that **1482 sheds light on an agency's performance of its statutory duties falls squarely within that statutory purpose.. indeed focuses on the citizens' right to be informed about ―what their government is up to. Kronman. 813. Bank and Customer. Legal Studies 727. (I. rule 24(a)(2). 89th Cong. of Justice v. The Privacy Exemption to the Freedom of Information Act..
U..Once government has identified cognizable privacy interest sought to be protected under Freedom of Information Act‘s (FOIA) law enforcement/privacy exemption.D. ordered the National Labor Relations Board to turn over to employer copies of all written statements of witnesses to be called in unfair labor practice proceeding.. § 552.Ct.the commercial interest of the requester. Justice Stevens filed a concurring opinion in which Mr.Cal.C.S. Freedom of Information Laws in General. **Gilmore v.Ed. § 552 .2d 724. Safety Bd. Ninth Circuit. Mr. Justice Brennan joined..L. 57 L. the Act was not intended to function as a private discovery tool. In General.1998 Basic purpose of Freedom of Information Act (FOIA) is to ensure an informed citizenry.2d 912 N.A. needed to check against corruption and to hold the governors accountable to the governed. we think it relevant to today's inquiry regarding the public interest in release of rap sheets on private citizens that **Congress once again expressed the core purpose of the FOIA as ―contribut[ing] significantly to public understanding of the operations or activities of the government. 2009 569 F. 242. vital to functioning of a democratic society.S.Supp. 2311. and certiorari was granted.C. 5 U. 563 F.3d 964 . 5 U. Justice Marshall. 437 U. Justice Powell filed an opinion concurring in part and dissenting in part in which Mr. needed to check against corruption and to hold the governors accountable to the governed. . only relevant public interest in FOIA balancing analysis is **extent to which disclosure of information sought would shed light on agency‘s performance of its statutory duties or otherwise let citizens know what their government is up to... 214.. of Energy. June 22. Dept. 5 U. Justice Rehnquist joined..  Records 326 50 [Cited 0 times for this legal issue] 326 Records 326II Public Access 326II(B) General Statutory Disclosure Requirements 326k50 k.A. Most Cited Cases (Formerly 326k14) **Basic purpose of the Freedom of Information Act is to ensure an informed citizenry.C.‖ 17. Although such a provision obviously implies that there will be requests that do not meet such a ―public interest‖ standard.S. N. Judgment of Court of Appeals reversed. Mr. Mr. 98 S. affirmed.A. v. Robbins Tire & Rubber Co. The Supreme Court.C..‖ 5 U.S. The Court of Appeals. United States Court of Appeals. vital to the functioning of a democratic society. Supp.S.R. V). held that release of statements of witnesses whom National Labor Relations Board intends to call at hearing on unfair labor practice complaint necessarily ―would interfere‖ with the Board's ―enforcement proceedings‖ and thus Board is not required to disclose such statements prior to hearing. Lahr v.2d 159 The United States District Court for the Northern District of Alabama. 4 F.B. Chief Justice Burger and Mr. §552(b)(7)(C). National Transp. and the Board appealed.S. § 552(a)(4)(A)(iii) (1982 ed.
see also NLRB v.S.Ct. 95 S... 1974 Source Book 38. vital to the functioning of a democratic society. needed to check against corruption and to hold the governors accountable to the governed..** The basic purpose of FOIA is to ensure an informed citizenry. Roebuck & Co. at 1517. Sears. 421 U. . at 152.
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