Wednesday, October 9, 2013
Re: Request for identity of individuals who provided information to Department of Housing and Urban Development relating to the initiation of certain HUD investigations Disposition: Affirming district court's grant of summary judgment to defendant
- Exemption 6: The court holds that "revealing [the complainant's] identities 'would constitute a clearly unwarranted invasion of personal privacy' under Exemption 6." The court first finds that, "in light of the repeated public pronouncements of [defendant]'s confidentiality policy," the authors of the complaints "have cognizable personal privacy interests under Exemption 6." The court then notes that the "district court noted in its opinion that [plaintiff] had 'mention[ed] the possibility of a civil lawsuit against the unidentified individuals for their 'sham' complaints,'" and, therefore, "conclude[s] that there is a significant risk of harassment, retaliation, stigma, or embarrassment of the authors if their identities are revealed." The court then finds that plaintiff "has not shown that learning the identities of those who wrote the letter or the email would add significantly to the already available information concerning the manner in which [defendant] has performed its statutory duties."
Court of Appeals
Updated August 6, 2014