Chrysler Corp. v. Brown

Supreme Court of the United States · 1979 · Administrative Law

Administrative LawFreedom of Information ActAdministrative Procedure ActTrade Secrets Actreverse-FOIAFOIA Exemption 418 U.S.C. § 1905Trade Secrets Act

Facts

Chrysler, a government contractor subject to Executive Orders 11246 and 11375, was required to submit affirmative-action programs, EEO-1 reports, and related compliance materials to the Department of Labor's compliance system through DLA. After third parties requested Chrysler's Newark and Hamtramck plant materials, DLA determined the documents would be disclosed under FOIA and OFCCP disclosure regulations. Chrysler objected and sought to enjoin disclosure, arguing that FOIA, 18 U.S.C. § 1905, and other confidentiality statutes barred release. The case centered on whether FOIA itself prohibited disclosure and whether the agency regulations supplied the legal authorization required by § 1905.

Issue

Does FOIA give a submitter of information a right to enjoin agency disclosure of material falling within a FOIA exemption? If not, do OFCCP disclosure regulations constitute authorization by law under 18 U.S.C. § 1905, and is agency disclosure reviewable under the APA?

Rule

FOIA is a disclosure statute; its exemptions define what an agency is not required to disclose, but they do not themselves prohibit disclosure or create a private right to enjoin disclosure. Under 18 U.S.C. § 1905, disclosure is authorized by law only if supported by authority having the force and effect of law, which requires that the regulation be substantive, rooted in a congressional delegation of legislative authority, and promulgated in compliance with applicable APA procedures. Although § 1905 creates no private right of action, alleged violations of § 1905 may render agency disclosure not in accordance with law and therefore reviewable under the APA.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Denver, a federal energy office receives a journalist's request for a contractor's fuel-supply spreadsheets. The office concludes the spreadsheets likely fall within FOIA Exemption 4 but decides to release them anyway under an internal transparency policy. The contractor, Mesa Vista Systems, sues solely on the theory that exempt material must be withheld under FOIA.

How should the court rule on the contractor's FOIA argument?

Explanation. The majority held that FOIA is a disclosure statute. Its exemptions define the scope of the agency's duty to disclose; they do not themselves prohibit disclosure or create a submitter's right to block release. A submitter must point to some separate legal bar, not FOIA alone. (Derived from Chrysler Corp. v. Brown (n.d.).)