What the Freedom of Information Act Means to American Businesses

The Freedom of Information Act is a commonly misunderstood document, partially because of the name. However, the fact of the matter is not everything is covered under the Freedom of Information Act. Citizens should be aware of what is and is not allowed under the act, the legal case brief below discusses a commonly addressed issue in United States Courts regarding the interpretation of the Freedom of Information Act.

Minnis v. United States Dep't of Agriculture

Legal Issue

Whether the plaintiff, Minnis, is entitled to the release of information laid out under the Freedom of Information Act, 5 U.S.C.S. § 552.

Conclusion

That the release of the information would result in an invasion of privacy, and that the plaintiff did not have a right to the information simply to benefit his commercial interests.

Facts

Mr. Minnis is the owner of a commercial lodge located on the bank of the Oregon's Rouge River. Every year the Forest Service controls the traffic of the Rouge River between Memorial Day and Labor Day by requiring all persons to acquire permits through a random computer lottery. Minnis filed a request with the Forest Service under the Freedom of Information Act in order to obtain the names and addresses of all the people who obtained permits. This would allow him to notify these permit holders of his available accommodations in the area. The request was denied by the Forest Service. Minnis then brought his action to the court who granted the request. The case was then appealed before the Ninth Circuit Court.

Legal Reasons/ Rationale

The court of appeals reversed the decision on the basis that the disclosure of information would have no clear benefit to the public as a whole and would in fact be more than a minimal invasion of privacy. The court used four factors from Van Bourg, Allen, Weinberg & Roger v. NLRB, Church of Scientology of California v. United States Department of the Army when determining an invasion of privacy is clearly unnecessary. "(1) The plaintiff's interest in disclosure; (2) the public interest in disclosure; (3) the degree of the invasion of personal privacy; and (4) the availability of any alternate means of obtaining the requested information." The court finds that the Freedom of Information Act was not designed to aid in personal gain and commercial interest. Without public interest the disclosure would be an invasion of privacy as highlighted in Wine Hobby USA, Inc. v. United States Internal Revenue Service, 502 F.2d 133 (3d Cir. 1974).