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National Labor Relations Board v. Robbins Tire & Rubber Co.

437 U.S. 214, 98 S. Ct. 2311, 57 L. Ed. 2d 159 (1978)

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National Labor Relations Board v. Robbins Tire & Rubber Co.

United States Supreme Court
437 U.S. 214, 98 S. Ct. 2311, 57 L. Ed. 2d 159 (1978)

  • Written by Robert Cane, JD

Facts

The National Labor Relations Board (NLRB) (defendant) issued an unfair-labor-practice complaint against Robbins Tire & Rubber Co. (Robbins) (plaintiff), relating to a union election. A hearing was scheduled. Robbins made a Freedom of Information Act (FOIA) request for copies of all potential witness statements collected by the NLRB during its investigation. The NLRB denied the request, claiming an exemption to FOIA. Exemption 7(A) provides for the nondisclosure of investigatory records if disclosure would interfere with enforcement proceedings. Robbins appealed the denial of its FOIA request to the district court. The district court held that Exemption 7(A) did not apply because the NLRB did not claim any danger of interference with enforcement in its decision to deny the request. The NLRB appealed to the appellate court, which affirmed the district court decision. The NLRB then appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Marshall, J.)

Concurrence/Dissent (Powell, J.)

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