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Prison Legal News v. Samuels, No. 05-1812, 2013 WL 3808045 (D.D.C. July 23, 2013) (Walton, J.)

Re: Request for documents showing all money paid by BOP for lawsuits and claims during a specified time period Disposition: Granting defendant's motions for summary judgment and denying plaintiff's motion for summary judgment
  • Exemption 6: The court holds that BOP properly applied Exemption 6 to withhold names and other personal identifying information that would reveal identities of persons related to claims filed under the Federal Tort Claims Act, and claims related to the Equal Employment Opportunity Commission and the Merit Systems Protection Board.  The court finds a privacy interest in information that would reveal "personal information about injuries, deaths, and allegations of discrimination."  The court further finds that "plaintiff's first stated interest in being better able to match certain documents with certain other documents identifies a particular purpose for how the information will be used . . . [but] does not constitute a proper public interest under Exemption 6."  The court likewise declines to accept plaintiff's argument "that there is a public interest 'in knowing how much money was used to settle claims against [defendant's] employees and officials,'" and that disclosure of names is necessary to serve this interest.  The court notes that "the requested information . . . consists entirely of the names and other personal identifying information . . .  of individuals who were not acting in an official capacity."  Furthermore, "plaintiff has identified no well-publicized scandal or other information, such as a public letter censuring particular employees . . . to serve as the public interest in disclosing the names and other identifying information."  Balancing the privacy interest against the public interest, the court concludes that "given the nature of the privacy interest at stake, i.e. public confirmation that particular individuals suffered deaths or other losses, and disclosure of details of various types of discrimination allegations made by or against particular individuals, and given also the lack of well-publicized scandal or other information suggesting that agency misconduct occurred within the timeframe of plaintiff's FOIA request . . . the public interest in knowing the names and other identifying information does not outweigh the individuals' privacy interests."
Court Decision Topic(s)
District Court opinions
Exemption 6
Updated August 6, 2014