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Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

lawsuitsummary judgmentcitizenship
regulationcitizenship

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McBurney v. Young, 569 U.S. 221, 133 S.Ct. 1709, 185 L.Ed.2d 758, 81 USLW 4276, 41 Media L. Rep. 1669, 13 Cal. Daily Op. Serv. 4228, 2013 Daily Journal D.A.R. 5477, 24 Fla. L. Weekly Fed. S 171

Facts

Petitioners Mark J. McBurney and Roger W. Hurlbert, citizens of Rhode Island and California respectively, filed requests under Virginia's FOIA for public records, which were denied due to their non-Virginia citizenship. McBurney sought documents related to child support enforcement, while Hurlbert requested real estate tax records. Both petitioners subsequently filed a lawsuit under 42 U.S.C. § 1983, claiming violations of their constitutional rights. The District Court granted summary judgment in favor of Virginia, and the Fourth Circuit affirmed.

Petitioners Mark J. McBurney and Roger W. Hurlbert are citizens of Rhode Island and California respectively. McBurney and Hurlbert each requested documents under the Virginia FOIA, but their requests were denied because of their citizenship.

Issue

Did Virginia's citizens-only FOIA provision violate the Privileges and Immunities Clause or the dormant Commerce Clause?

Did Virginia's citizens-only FOIA provision violate the Privileges and Immunities Clause or the dormant Commerce Clause?

Rule

The Privileges and Immunities Clause protects only fundamental privileges and immunities, and the dormant Commerce Clause prohibits states from enacting laws that unduly burden interstate commerce.

The Privileges and Immunities Clause protects only those privileges and immunities that are 'fundamental.'

Analysis

The Court found that Virginia's FOIA does not violate the Privileges and Immunities Clause because the law serves a nonprotectionist purpose, allowing Virginia citizens to hold public officials accountable. The distinction between citizens and noncitizens does not impose significant burdens on noncitizens' rights to earn a living or access public information. Additionally, the FOIA does not regulate interstate commerce in a way that would trigger dormant Commerce Clause scrutiny.

Virginia's FOIA, by contrast, neither prohibits access to an interstate market nor imposes burdensome regulation on that market.

Conclusion

The Supreme Court affirmed the lower court's ruling, concluding that Virginia's citizens-only FOIA provision does not violate the Privileges and Immunities Clause or the dormant Commerce Clause.

Accordingly, this is not properly viewed as a dormant Commerce Clause case.

Who won?

Virginia prevailed in the case because the Supreme Court found that the citizens-only provision of the FOIA did not infringe upon the constitutional rights of noncitizens.

Virginia prevailed in the case because the Supreme Court found that the citizens-only provision of the FOIA did not infringe upon the constitutional rights of noncitizens.

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