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Church of Scientology v. Department of Justice

612 F.2d 417 (1979)

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Church of Scientology v. Department of Justice

United States Court of Appeals for the Ninth Circuit
612 F.2d 417 (1979)

  • Written by Liz Nakamura, JD

Facts

The Church of Scientology of California (CSC) (plaintiff) submitted a Freedom of Information Act (FOIA) request to the Drug Enforcement Administration (DEA) (defendant) for any documents in the DEA’s possession regarding CSC. The DEA denied CSC’s request, citing FOIA Exemption 7(D), which protected information gathered by law enforcement from confidential sources. After exhausting all available administrative remedies, CSC sued the DEA in federal district court. In hearings before the district court, the DEA argued that Exemption 7(D) applied because the records CSC requested had been compiled by the DEA as part of a criminal investigation using information provided by confidential sources. The DEA further argued that the term “confidential sources” should be defined to include state, local, and foreign law-enforcement agencies, not just human sources. It was undisputed that there was no statutory definition for the term “confidential sources.” The district court, citing both Exemption 7(D)’s inconclusive legislative history and its facially unambiguous plain meaning, agreed with the DEA and held that Exemption 7(D) blocked CSC’s FOIA request. CSC appealed to the Ninth Circuit.

Rule of Law

Issue

Holding and Reasoning (Barnes, J.)

Dissent (Wallace, J.)

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