Taylor v. Babbitt

760 F. Supp. 2d 80 (2011)

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Taylor v. Babbitt

United States District Court for the District of Columbia
760 F. Supp. 2d 80 (2011)

RW

Facts

In 1935, the Fairchild Aircraft Corporation (Fairchild) filed design specifications for its model F-45 airplane with the predecessor to today’s Federal Aviation Administration (FAA). At the time, those specifications constituted trade secrets. In 1955, by which time the F-45 was obsolete and no longer in production, Fairchild sent the FAA a letter authorizing the FAA to loan the F-45 specifications to members of the public, without any obligation on the FAA’s part to maintain the confidentiality of those specifications. However, in 1997, when Greg Herrick submitted a Freedom of Information Act (FOIA) request for the FAA’s F-45 specifications, Fairchild renounced the 1955 letter and asserted that the specifications remained Fairchild’s trade secrets. Accordingly, the FAA denied Herrick’s request under the FOIA’s Exemption 4, which prohibited a government agency from disclosing commercially valuable trade secrets in its possession. The Tenth Circuit Court of Appeals upheld the FAA’s denial. In 2002, by which time Fairchild was no longer engaged in the aircraft industry, Brent Taylor (plaintiff) submitted another FOIA request for the FAA’s F-45 specifications. Once again, the FAA cited Exemption 4 and denied the request. Taylor brought suit against J. Randolph Babbitt (defendant), the FAA’s administrator, in the federal district court for the District of Columbia. The FAA cited Fairchild’s 1997 letter as proof that the F-45 specifications remained secret. The FAA acknowledged that obsolete 1935 design specifications no longer had commercial value to the aircraft industry. However, the FAA argued that the F-45 specifications retained commercial value on the market for antique aircraft. Taylor and the FAA each moved for summary judgment.

Rule of Law

Issue

Holding and Reasoning (Urbina, J.)

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