In Department of Air Force v. Rose (425 U.S. 352 (1976)), Rose was an Air Force officer in law school. He was writing an article about the military academies and filed a Freedom of Information Act (FOIA) request for information about disciplinary actions against individual cadets. The Air Force claimed that they were exempt under FOIA §552(b)(2) and §552(b)(6), because the documents were internal personal files that “held no interest to the general public.” The US Supreme Court ordered the documents released.

  • The US Supreme Court looked at the legislative history of §552(b)(2) (“internal personnel rules and files”) and found that there was a legitimate public interest in knowing about cadet discipline, since public tax dollars funded the school.
    • The Court found that §552(b)(2) is really only designed to protect very trivial minutia from being requested (due to administrative burdens in collecting the information).
  • The Court looked to §552(b)(6) (“personnel/medical and other files the disclosure of which would violate personal privacy”) and found that it meant Agencies had to reasonably separate personal information from non-protected information (by redacting the names and identifying info), and then still release what remained.