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eBook details

• Title: Spirko v. United States Postal Service
• Author : District of Columbia Circuit U.S. Court of Appeals
• Release Date : January 07, 1998
• Genre: Law,Books,Professional & Technical,
• Pages : * pages
• Size : 68 KB

Description

Argued May 11, 1998 The main issue in this appeal is whether the district court abused its discretion in conducting an in camera inspection of documents requested under the Freedom of Information Act, 5 U.S.C. § 552 (1994) (""FOIA""), without first ordering the agency to produce a more detailed description of the withheld documents in accordance with Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973). John G. Spirko, Jr., appeals from the grant of summary judgment to the United States Postal Service in his FOIA action, contending that the Postal Service did not satisfy its obligation under Vaughn to justify its decision to withhold requested documents, and that the district court erred by reviewing the documents in camera rather than ordering further Vaughn indexing by the agency. Spirko also contends that the district court, after conducting its in camera inspection, erred in finding that certain documents were properly withheld pursuant to Exemption 7(C) of FOIA, which allows agencies to withhold documents compiled for law enforcement purposes whose disclosure ""could reasonably be expected to constitute an unwarranted invasion of personal privacy."" 5 U.S.C. § 552(b)(7)(C). Alleging that the Postal Service withheld exculpatory evidence during his criminal trial and engaged in other wrongdoing, he contends that the public interest in exposing this misconduct is sufficient to remove the documents from Exemption 7(C). We find no abuse of discretion by the district court in deciding that in camera review would provide the most expeditious and fair resolution of Spirko's FOIA request. Furthermore, we agree with the district court that the requested documents are unrelated to Spirko's allegations of agency misconduct and, therefore, the documents were properly withheld under Exemption 7(C). Accordingly, we affirm. I.

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