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Lam Lek Chong v. United States Drug Enforcement Administration

929 F.2d 729 (1991)

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Lam Lek Chong v. United States Drug Enforcement Administration

United States Court of Appeals for the District of Columbia Circuit
929 F.2d 729 (1991)

MJ

Facts

Lam Lek Chong (plaintiff) was prosecuted and convicted of a criminal offense. During those proceedings, Lam Lek Chong learned that the United States Drug Enforcement Administration (DEA) (defendant) had gathered audio recordings of him but that the recordings were not introduced at trial or given to his attorneys. Lam Lek Chong then made a request for the recordings under the Freedom of Information Act (FOIA). Although the DEA turned over some information, it also withheld some information. Eventually, Lam Lek Chong sued the DEA, claiming that the FOIA entitled him to full production of the information requested. As relevant here, the district court granted summary judgment for the DEA. The court concluded that transcripts of electric interceptions that were made pursuant to Title III of the Omnibus Crime Control and Safe Streets Act of 1968 (Title III) did not have to be disclosed under the FOIA if they were specifically exempted from disclosure under a statute. Lam Lek Chong appealed.

Rule of Law

Issue

Holding and Reasoning (Edwards, J.)

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