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litigationattorneyappealtrialaffidavitattorney-client privilege

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Mead Data Central, Inc. v. U.S. Dept. of Air Force, 566 F.2d 242, 184 U.S.App.D.C. 350, 3 Media L. Rep. 1001

Facts

In early 1975, Mead Data filed a FOIA request with the Air Force for documents related to Project FLITE, a computerized legal research system. The Air Force agreed to disclose some documents but withheld eight, claiming they were exempt under FOIA exemption five as attorney work products or intra-agency memoranda. Mead Data appealed the decision, leading to a lawsuit seeking disclosure of the withheld documents.

In early 1975, Mead Data filed a FOIA request with the Air Force seeking disclosure of several categories of documents dealing generally with the Department's 'Project FLITE,' a computerized legal research system.

Issue

Whether the documents requested by Mead Data are exempt from disclosure under exemption five of the FOIA, which protects intra-agency memoranda and attorney-client communications.

The Court of Appeals, Tamm, Circuit Judge, held that the trial court's interpretation of the applicable FOIA exemption was impermissibly broad, and that remand was therefore necessary for further proceedings under the narrower constructions outlined on appeal.

Rule

Exemption five of the FOIA exempts from mandatory disclosure intra-agency memoranda or letters that would not be available by law to a party other than an agency in litigation with the agency, including materials protected by the attorney-client privilege.

Exemption five of the FOIA exempts from mandatory disclosure those matters that are 'intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with the agency.'

Analysis

The court analyzed the nature of the withheld documents and determined that while some documents contained legal opinions and recommendations that could be protected under the attorney-client privilege, others were merely factual and did not meet the criteria for exemption. The court emphasized that the Air Force's broad interpretation of the exemption was not justified and that the agency must provide specific reasons for withholding each document.

The court noted that although the Air Force's initial description of the withheld documents hardly comported with the requirements of Vaughn v. Rosen and Cuneo v. Schlesinger, the elaborated description contained in the affidavits it had submitted to the court was adequate.

Conclusion

The Court of Appeals reversed the district court's judgment regarding some documents and remanded the case for further proceedings to determine if the Air Force could adequately justify withholding the documents under the claimed exemptions.

We therefore reverse the district court's judgment that documents 1 and 5 are covered by the attorney-client privilege component of exemption five.

Who won?

The Court of Appeals ruled in favor of Mead Data by remanding the case for further proceedings, indicating that the Air Force's claims for exemption were overly broad.

We agree with Mead Data that the objective of the Vaughn requirements, to permit the requesting party to present its case effectively, is equally applicable to proceedings within the agency.

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