The Bureau of National Affairs, Inc. v. United States Department of Justice
United States District Court for the District of Columbia
742 F.2d 1484 (1984)
Relevant factsFree
The Bureau of National Affairs (BNA) (plaintiff) sought disclosure under the Freedom of Information Act (FOIA) of appointment and meeting records for a DOJ official, William Baxter, while the Environmental Defense Fund (EDF) (plaintiff) separately sought similar appointment calendars and phone logs for OMB officials. Both DOJ and OMB (defendants) refused, arguing the materials weren't "agency records" subject to FOIA disclosure, and the cases were consolidated.
IssueFree
Whether government officials' personal appointment materials -- phone message slips, appointment calendars, and daily agendas -- qualify as "agency records" subject to disclosure under FOIA.