ADMINISTRATIVE APPEALS

During 1978, there were 2,922 new administrative appeals received by the Office of Privacy and Information Appeals and 2,988 appeals were closed. With a pending caseload at the beginning of the year of 996, there were 930 cases on hand at the end of the year.

Of the 2,988 cases closed during the year, 968 involved requests under the Freedom of Information Act. The breakdown of these closings is as follows:

- Modified Action Resulting in Total Grant 10
- Reversed(1) 31
- Affirmed 311
- Modified Action Affirmed(2) 196
- Miscellaneous 420

The miscellaneous closings consist of the following:

- Failure of the component to process initial action within statutory time limit(3)

145
- Inventory adjustment(4) 60
- Miscellaneous (e.g., individual appeal consolidated into "subject matter appeal"; judicial adjudication; all requested information had been released; appeal file erroneously opened; etc. 50
- No records 31
- Requester withdrew appeal 34

- No agency jurisdiction (appeals from state, local or other Federal agency actions)

24

- Fee waivers denied

59

- Duplicate file

17

The statutory provisions on the bases of which denials of Freedom of Information requests were predicated at the administrative appeals level are as follows:

5 U.S.C. § 552(b)(1) 106
5 U.S.C. § 552(b)(2) 47
5 U.S.C. § 552(b)(3) 42
5 U.S.C. § 552(b)(4) 11
5 U.S.C. § 552(b)(5) 42
5 U.S.C. § 552(b)(6) 51
5 U.S.C. § 552(b)(7)(A) 60
5 U.S.C. § 552(b)(7)(B) 2
5 U.S.C. § 552(b)(7)(C) 336
5 U.S.C. § 552(b)(7)(D) 281
5 U.S.C. § 552(b)(7)(E) 73
5 U.S.C. § 552(b)(7)(F) 8
5 U.S.C. § 552(b)(8) 1
5 U.S.C. § 552(b)(9) 1
5 U.S.C. § 551(1)(B) 11

Exemption 3 was asserted at the administrative appeals level in conjunction with the following statutes:

Rule 6(e), Federal Rules of Criminal Procedure 27
15 U.S.C. § 16(b)-(h)(5) 1
15 U.S.C. § 1313 4
18 U.S.C. § 701 1
18 U.S.C. § 2518 2
26 U.S.C. § 6103 4
50 U.S.C. § 403 3

The final actions on Freedom of Information administrative appeals involving continued denials of access to requested records were taken by the following officials:

Attorney General Griffin B. Bell . . . . . . . 2

Deputy Attorney General Benjamin R. Civiletti . . . . .1

Associate Attorney General Michael J. Egan . . . . . 3

Deputy Attorney General Benjamin R. Civiletti
by Quinlin J. Shea, Jr.,
Director, Office of Privacy and Information Appeals . . . . . . . . . . 413

Associate Attorney General Michael J. Egan
by Quinlin J. Shea, Jr.,
Director, Office of Privacy and Information Appeals . . . . . . . . . . 129

All miscellaneous closings were effected the Director of the Office of Privacy and Information Appeals, either in his own name or for the Deputy Attorney General or the Associate Attorney General.

In addition to the 968 Freedom of Information administrative appeals closed this year, 2,020 "Privacy Act" (first party request)(6) administrative appeals were also closed. The breakdown of the Privacy Act appeal closings is as follows:

Modified Action Resulting in Total Grant 13
Reversed(7) 25
Affirmed 568
Modified Action Affirmed(8) 596
Miscellaneous 818

The miscellaneous closings consist of the following:

- Failure of the component to process initial action within statutory time limit(9)

346
- Inventory adjustment(10) 121
- Miscellaneous (e.g., individual appeal consolidated into "subject matter appeal"; judicial adjudication; all requested information had been released; appeal file erroneously opened; etc. 123
- No records 44
- Requester withdrew appeal 34
- Requester died 1

- No agency jurisdiction (appeals from state, local or other Federal agency actions)

45

- Fee waiver denied

104
- Amendment/Expunction (3 granted, 23 denied) 26

- Duplicate file

29

The statutory provisions on the basis of which denials of first party requests for access were predicated at the administrative appeals level were as follows:

5 U.S.C. § 552a(d)(5) 7
5 U.S.C. § 552a(k)(1) 28
5 U.S.C. § 552a(k)(2) 9
5 U.S.C. § 552a(k)(5) 62
5 U.S.C. § 552(b)(1) 316
5 U.S.C. § 552(b)(2) 106
5 U.S.C. § 552(b)(3) 69
5 U.S.C. § 552(b)(4) 3
5 U.S.C. § 552(b)(5) 49
5 U.S.C. § 552(b)(6) 60
5 U.S.C. § 552(b)(7)(A) 95
5 U.S.C. § 552(b)(7)(B) --
5 U.S.C. § 552(b)(7)(C) 838
5 U.S.C. § 552(b)(7)(D) 782
5 U.S.C. § 552(b)(7)(E) 235
5 U.S.C. § 552(b)(7)(F) 58
5 U.S.C. § 551(1)(B) 53

Exemption 3 of the Freedom of Information Act was asserted at the administrative appeals level in conjunction with the following statutes:

Rule 6(e), Federal Rules of Criminal Procedure 51
18 U.S.C. § 2518 3
26 U.S.C. § 6103 5
50 U.S.C. § 403 8
"note" to 18 U.S.C. § 3481 (Public Law 91-452) 1

The final actions on Privacy Act administrative appeals involving continued denials of access to requested records were taken by the following officials:

Deputy Attorney General Benjamin R. Civiletti . . . . . . . . . . . .. . . . . . . . . . . . . .4

Associate Attorney General Michael J. Egan . . . . . . . . . . . . . . . . . . . . .1

Deputy Attorney General Benjamin R. Civiletti
by Quinlin J. Shea, Jr.,
Director, Office of Privacy and Information Appeals . . . . . . . . . . . . . . .821

Associate Attorney General Michael J. Egan
by Quinlin J. Shea, Jr.,
Director, Office of Privacy and Information Appeals . . . . . . . .. . . .. . . . . . . . . 357

All miscellaneous closings were effected the Director of the Office of Privacy and Information Appeals, either in his own name or for the Deputy Attorney General or the Associate Attorney General.

The costs of processing administrative appeals are as follows: (11)

Freedom of Information Act related expenses:
Services $482,000
Other 28,400
Total $510,400
Privacy Act related expenses:
Services $10,000
Other 600
Total $10,600





**** footnotes ****

1 This includes 21 appeals in which the cases were remanded to the components with instructions to reprocess, or process, the relevant records. Reprocessing follows a determination that the processing was initially carried out under a significantly erroneous standard. A remand for processing results from a determination that a refusal to process requested records, or to confirm or deny their existence, was erroneous.

2 These represent modifications of initial actions arrived at in the course of the appeals process by agreement between the component and the appeals office.

3 Upon receipt of an appeal based on the component's failure to locate and process requested records within the statutory time limits, the appeals office informs the component of the appeal, but advises the requester that it lacks the personnel resources to conduct the comprehensive record reviews necessary to make initial determinations on requested records. The appeals office also advises the requester that if he or she is dissatisfied with the component's substantive action on the request, an appeal on the merits will be opened. The requester is also informed that he or she may treat this notification from the appeals office as a denial of the appeal and bring suit in an appropriate Federal court. It has been the experience of the appeals office that a significant number of appeals based on actual denials of access, as opposed to appeals based on a component's failure to respond, considerably narrow the volume of records and issues that must be considered. Accordingly, this approach contributes to the efficient operation of the overall appeals process, without ever actually denying a requester the right to a review of an initial action on the merits.

4 As the result of quarterly inventories of cases actually open in the office (a practice initiated in 1978), it was determined that, during the years 1975-1977, final actions were in fact taken on 181 access appeals which had not been officially logged out. In order to accurately reflect the actual pending appeals load at the end of the year, these appeals were added to this year's total appeals closed count. Assuming that the ratio of Freedom of Information Act cases to Privacy Act cases within this group of 181 was the same as with the access appeals actually processed in 1978, it is estimated that 60 of the 181 appeals were under the Freedom of Information Act and 121 under the Privacy Act.

5 Cited, alternatively, with 5 U.S.C. 552(b)(4).

6 In conformity with Department of Justice regulations, all requests by individuals seeking access to records about themselves are, to the extent possible, treated as Privacy Act requests. 28 C.F.R. 16.57. In fact, however, given the nature of the records requested and the systems of records within which they are maintained (most of which have been exempted from Privacy Act access pursuant to 5 U.S.C. § 552a(j)(2)), it is quite rare for actual denials of access to be predicated on specific Privacy Act exemptions. Such exemptions were cited in approximately 3% of the cases adjudicated by the appeals office and, in most of those cases, FOIA exemptions were cited as well. Nonetheless, all first-party requests are being treated as Privacy Act for purposes of case count. For purposes of cost apportionment, however, only 2% are being allocated to the Privacy Act.

7 See note 1, supra. This includes 19 appeals in which the cases were remanded.

8 See note 2, supra.

9 See note 3, supra.

10 See note 2, supra.

11 See note 6, supra.


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