Ray v. Turner
United States Court of Appeals for the District of Columbia
587 F.2d 1187 (1978)
Ellen Ray and William Schaap (plaintiffs) requested their own files from the CIA (defendant) under the Freedom of Information Act, and when the CIA refused disclosure, they sued, moving for in camera review of the documents while the government moved for summary judgment supporting nondisclosure based on affidavits from CIA Chief of Operations Staff Eloise Page describing the documents and the government's claimed exemptions under FOIA Exemptions 1 (classified material) and 3 (statutorily exempted material). The district court granted the government's motion and denied in camera review, finding the documents exempt.
Whether, in Freedom of Information Act cases implicating national security concerns, in camera inspection of withheld documents is permitted at the court's discretion.