United States Department of Defense v. Federal Labor Relations Authority

510 U.S. 487, 114 S. Ct. 1006, 127 L. Ed. 2d 325 (1994)

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United States Department of Defense v. Federal Labor Relations Authority

United States Supreme Court

510 U.S. 487, 114 S. Ct. 1006, 127 L. Ed. 2d 325 (1994)

Facts

Two public unions submitted Freedom of Information Act (FOIA) requests to the Department of Defense (DOD) (defendant), seeking federal government employee addresses of employees in bargaining units that were represented by unions. The DOD refused to provide home addresses. As a result, the unions filed a claim with the Federal Labor Relations Authority (FLRA) for unfair labor practices, arguing that the Federal Service Labor-Management Relations Statute (Labor Statute) required agencies to provide unions with the home addresses as necessary data for collective-bargaining purposes. The DOD claimed that the Privacy Act of 1974 and FOIA Exemption 6 prohibited disclosure. The FLRA found in favor of the unions and ordered disclosure of the home addresses. The case was appealed to the United States Court of Appeals for the Fifth Circuit, which affirmed the FLRA’s order. The appellate court reasoned that the public interest in collective bargaining promoted by the Labor Statute outweighed individual privacy concerns. The DOD appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Thomas, J.)

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