Federal Bureau of Investigation v. Abramson
Supreme Court
456 U.S. 615 (1982)
Investigative reporter Howard Abramson sought records under the Freedom of Information Act relating to a 1969 transmittal of information from the FBI (defendant here as the agency withholding records) to the White House about individuals who had criticized the administration. After partial disclosure and litigation, Abramson narrowed his request to material withheld from a single "name check" memorandum from J. Edgar Hoover to a White House aide, which itself contained 63 pages of summaries and attachments drawn from FBI files on 11 public figures. The district court found the FBI hadn't shown the information was compiled for law enforcement rather than political purposes, but ruled for the FBI anyway on privacy grounds; the court of appeals reversed, and the FBI appealed.
Whether information exempt from FOIA disclosure because it was compiled for law enforcement purposes loses that exemption when it is later incorporated into a record compiled for a different, non-law-enforcement purpose.