Federal Communications Commission v. AT&T, Inc.

562 U.S. 397, 131 S. Ct. 1177, 179 L. Ed. 2d 132 (2011)

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Federal Communications Commission v. AT&T, Inc.

United States Supreme Court
562 U.S. 397, 131 S. Ct. 1177, 179 L. Ed. 2d 132 (2011)

Facts

The Freedom of Information Act (FOIA) requires federal agencies to provide documents to members of the public upon request, subject to certain statutorily defined exemptions. FOIA Exemption 7(c) prevents the disclosure of law-enforcement records that “could reasonably be expected to constitute an unwarranted invasion of personal privacy.” A FOIA request was filed, requesting the disclosure of records related to the participation of AT&T, Inc. (AT&T) (plaintiff) in a program administered by the Federal Communications Commission (FCC) (plaintiff). The Federal Bureau of Investigations (FBI) issued a letter ruling declining to apply Exemption 7(c) to AT&T, reasoning that corporations do not have personal privacy rights. The FCC agreed with the FBI. AT&T appealed, arguing that corporations fall within the statutory definition of “person” and thus possess personal privacy rights. The court of appeals found for AT&T, holding that a corporation may have a personal privacy interest within the meaning of Exemption 7(c). The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Roberts, J.)

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