Freedom of Information Act: Information from Answers.com

What Types of Information Have Been Requested?
The following have been requested under the Freedom of Information Act:
• Documents relating to underground nuclear testing.
• CIA records on whether the agency played a role in the assassination of John F. Kennedy or obstructed its investigation.
• Documents on Richard Nixon's use of the FBI to dig up "dirt" on political opponents.
• CIA files about sightings of unidentified flying objects (UFOs).
• Payroll reports submitted by nonunion contractors (requested by an electricians' union).
• CIA documents about the Bay of Pigs invasion of Cuba.
• Records of the Environmental Protection Agency about the agency's compliance with its federally mandated duties.
• Reports on Vietnam-era prisoners of war and soldiers listed as missing in action.

The Freedom of Information Act (P.L. 89-554, 80 Stat. 383) asserts the public's right to know about the activities of government. That right to know is the foundation of accountability in a democracy and in fact preserves democratic government. The First Amendment right of free speech draws power from the availability of information, because knowledge enables people to identify government misconduct or incompetence and challenge government actions. Lacking access to information about government weakens the right to speak and the right to associate with others to advocate for change. Criticism without information is less powerful; ignorance dulls outrage and reduces the incentives to organize for democratic change. The supporters of the act often quote James Madison, the fourth president of the United States: "Knowledge will forever govern ignorance. And a people who mean to be their own governors, must arm themselves with the power knowledge gives. A popular government without popular information or the means of acquiring it is but a prologue to a farce or a tragedy or perhaps both."

"Any-Person Access"

Before passage of the act, the existing administrative provisions required people seeking government documents to state why they wanted them and allowed government officials to decide whether the interests in disclosure outweighed the interests in secrecy. Not surprisingly, these officials usually denied access to requested documents. Government officials also withheld rulings and standards used to exercise governmental authority, thereby creating a type of "secret law." The act amended these provisions to require that certain types of records be made available for public inspection. These documents include statements of policy and interpretations of rules and policies not published in the Federal Register, final opinions resulting from agency adjudications, and manuals that are not offered for sale but that affect a member of the public.

Other documents and records are to be available on request to "any person." Requesters do not have to explain why they want the documents. Any-person access and the policy that government documents and records are public strengthens the public's right to know and reduces the discretion of governmental officials.

The law also establishes detailed procedures for requests and provides for administrative appeals of denials of requests. These procedures also address issues such as the time limits for responding to requests, the fees that may be charged (as well as the possibility of waivers or reductions of fees), and other obligations of the agency. One crucial provision requires that the agency segregate documents that can be withheld from ones that should be disclosed. Most important, a requester who has unsuccessfully sought documents from a government agency may ask a federal district court to order an agency to disclose these documents. In this suit, the federal court is bound neither by an agency's determinations of fact nor by its interpretation of the act. The federal courts have often ordered the disclosure of withheld documents, and judicial decisions have interpreted and given effect to many parts of the law.

Exemptions

The act, however, permits government officials to withhold documents that fall under one of nine exemptions contained in the law. These exemptions address documents:

Properly classified in the interests of national defense or foreign policy
That are internal guides discussing enforcement strategies, the release of which would risk evasion of the law
The disclosure of which is specifically prohibited by other laws
Containing confidential or privileged commercial or financial information
Protected by litigation privileges, including the attorney-client, work product and deliberative process privileges
The release of which would constitute a clearly unwarranted invasion of personal privacy
Compiled for law-enforcement purpose, the release of which would, or in some instances could reasonably be expected to, create the risk of certain harms
Contained in or related to oversight of financial institutions by an agency charged with regulation or supervision of such institutions
Containing geophysical and geological information regarding oil wells

Generally, these exemptions allow government officials only to withhold documents but do not require them to do so. However, other laws, such as those protecting personal privacy, controlling the dissemination of classified information, or specifically requiring withholding are exceptions to this general rule.

Much of the litigation under the act has focused on the meaning of the exemptions. The exemptions addressing national security, the deliberative process within and among federal agencies, the protection of business records, personal privacy, and law enforcement records have generated the most litigation. The Supreme Court has emphasized that the exemptions to the act must be "narrowly construed." A narrow interpretation of the scope of the exemptions prevents them from swallowing the general principles of the act requiring access to government documents.

Amendments

Although the act has been amended on a number of occasions, the most important amendments occurred in 1974 and in 1996. The 1974 amendments responded to agency practices thought to demonstrate an unwillingness to apply the right-to-know principle underlying the law. These amendments strengthened deadlines for agency responses, regulated fees and fee waivers, and provided for personal sanctions against federal officials who acted arbitrarily in withholding requested documents. These amendments also revised the exemption regarding national security information: they reversed an interpretation by the Supreme Court that denied federal judges the authority to determine whether classified documents were in fact properly classified. The amendments also responded to decisions that had expanded the scope of the law enforcement exemption. In these amendments Congress signaled its continuing support of the principle of open government and its willingness to address bureaucratic opposition to the law.

The Electronic Freedom of Information Act of 1996 (EFOIA) also changed procedures under the act to address the problem of agency delay in responding to requests. EFOIA expands the time that agencies have to respond to an initial request in an attempt to create more realistic standards for agencies. It also directs agencies to create categories of requesters whose requests can be considered on other than a first-come, first-served basis. These categories include requesters who can demonstrate that failure to obtain quickly requested records would endanger the life or physical safety of a person, and also requesters primarily involved in the dissemination of information to the public, if their requests are ones urgently requiring that the public be informed about "actual or alleged Federal Government activity." EFOIA allows agencies to create different avenues for processing requests, such as by considering large and small requests in different groups. It also limits the ability of agencies to use "exceptional circumstances" as an excuse for delay resulting from agencies' ordinary backlogs.

EFOIA modifies the act for an electronic age. It broadly defines electronic records, includes library and reference materials within the definition of record, increases the ability of requesters to obtain documents in electronic form, directs agencies to conduct electronic searches, and considers how agencies should treat computerized removal of exempt information from request documents.

Most important, EFOIA imposes greater responsibilities on agencies to disseminate information rather than simply respond to requests. Now, agencies are required to make available any documents that "have become or are likely to become the subject of subsequent requests for substantially the same records." These records must be provided online in virtual reading rooms that a person can access without physically appearing at an agency. Agencies are also required to publish indices and guides that will help in framing a request. These changes shift the standard procedure from a request-and-respond model of access to one that relies more heavily on dissemination of information by the government.

Requests By Private Parties

Many users of the act are private parties rather than newspapers, television stations, and other media. The government holds not only information that it has created but also information that has been submitted to it. Much of this information does not directly concern the performance of government officials. For example, businesses seek documents from the government about their competitors, and consumers seek documents relating to health and safety information concerning consumer products or information about consumer frauds or other illegal business practices. In this sense, the act has helped to support competition among firms and to provide consumers with information to participate efficiently in the market.

Requests by private parties also support the principle of government accountability. For example, government contractors can acquire information about successful bidders. This not only serves the contractors' own commercial interests but also helps to ensure that the contracting process operates fairly. Government documents about risks to public health and safety also reinforce the responsibility of the government to attend to those risks.

The United States Freedom of Information Act is not the oldest in the world, but it has been one of the most influential. Dozens of countries, including ones with a reputation for bureaucratic secrecy, such as Great Britain and Japan, have adopted freedom of information laws. Countries throughout the world, including many nations in Eastern Europe and countries that were once part of the Soviet Union, have adopted such laws as an important step in their transition to democratic government.

Bibliography

Leahy, Patrick, et al. "Recent Developments: Electronic Freedom of Information Act." Administrative Law Review 50 (1998): 339–458.

O'Reilly, James T. Federal Information Disclosure. Colorado Springs, CO: Shepard's, 1977.

This article is about the U.S. law. For freedom of information in other countries, see freedom of information legislation.

The Freedom of Information Act (FOIA), as amended, represents the implementation of freedom of information legislation in the United States.^[1] It was signed into law by President Lyndon B. Johnson on September 6, 1966 (Public Law 89-554, 80 Stat. 383; Amended 1996, 2002, 2007),^[2] and went into effect the following year. This act allows for the full or partial disclosure of previously unreleased information and documents controlled by the United States Government. The Act defines agency records subject to disclosure, outlines mandatory disclosure procedures and grants nine exemptions to the statute. ^[3] The law was ratified in 1966, coincidentally 200 years after what is believed to be the first Freedom of Information Legislation, Sweden's Freedom of the Press Act, in 1766.

Background

With the ongoing stress on both constitutional and inherent rights of American citizens and the added assertion of government subservience to the individual, some thought it was necessary for government information to be available to the public.

However, the sensitivity of some government information and private interests clash with this view. Therefore, Congress attempted to enact a Freedom of Information Act in 1966 that would effectively deal with requests for government records, consistent with the belief that the people have the “right to know” about them. The Privacy Act of 1974 additionally covered government documents charting individuals.

However, it is in the exemptions to solicitation of information under these acts that problems and discrepancies arise. The nine exemptions to the FOIA address issues of sensitivity and personal rights. They are (as listed in Title 5 of the United States Code, section 552):^[4]

(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign policy and (B) are in fact properly classified pursuant to such Executive order;^[5]
related solely to the internal personnel rules and practices of an agency;^[5]
specifically exempted from disclosure by statute (other than section 552b of this title), provided that such statute (A) requires that the matters be withheld from the public in such a manner as to leave no discretion on the issue, or (B) establishes particular criteria for withholding or refers to particular types of matters to be withheld;^[5]
trade secrets and commercial or financial information obtained from a person and privileged or confidential;^[5]
inter-agency or intra-agency memoranda or letters which would not be available by law to a party other than an agency in litigation with the agency;^[5]
personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;^[5]
records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or information (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could reasonably be expected to disclose the identity of a confidential source, including a State, local, or foreign agency or authority or any private institution which furnished information on a confidential basis, and, in the case of a record or information compiled by a criminal law enforcement authority in the course of a criminal investigation or by an agency conducting a lawful national security intelligence investigation, information furnished by a confidential source, (E) would disclose techniques and procedures for law enforcement investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could reasonably be expected to risk circumvention of the law, or (F) could reasonably be expected to endanger the life or physical safety of any individual;^[5]
contained in or related to examination, operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible for the regulation or supervision of financial institutions;^[5] or
geological and geophysical information and data, including maps, concerning wells.^[5]

Scope

The act explicitly applies only to federal government agencies. These agencies are under several mandates to comply with public solicitation of information. Along with making public and accessible all bureaucratic and technical procedures for applying for documents from that agency, agencies are also subject to penalties for hindering the process of a petition for information. If “agency personnel acted arbitrarily or capriciously with respect to the withholding, [a] Special Counsel shall promptly initiate a proceeding to determine whether disciplinary action is warranted against the officer or employee who was primarily responsible for the withholding.” ^[6] In this way, there is recourse for one seeking information to go to a Federal court if suspicion of illegal tampering or delayed sending of records exists. However, there are nine exemptions, ranging from a withholding “specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign policy” and “trade secrets” to “clearly unwarranted invasion of personal privacy.” ^[6]

The Privacy Act Amendments of 1974

Following the Watergate scandal, President Gerald R. Ford wanted to sign Freedom of Information Act-strengthening amendments in the Privacy Act of 1974, but concern (by his chief of staff Donald Rumsfeld and deputy Richard Cheney) about leaks and legal arguments that the bill was unconstitutional (by government lawyer Antonin Scalia, among others) persuaded Ford to veto the bill, according to documents declassified in 2004.^[7] However, Congress voted to override Ford's veto, giving the United States the core Freedom of Information Act still in effect today, with judicial review of executive secrecy claims.^[8] ^[9]

These amendments to the FOIA regulate government control of documents which concern a citizen. It gives one “(1) the right to see records about [one]self, subject to the Privacy Act's exemptions, (2) the right to amend that record if it is inaccurate, irrelevant, untimely, or incomplete, and (3) the right to sue the government for violations of the statute including permitting others to see [one’s] records unless specifically permitted by the Act.”^[10] In conjunction with the FOIA, the PA is used to further the rights of an individual gaining access to information held by the government. The Justice Department's Office of Information and Privacy and federal district courts are the two channels of appeal available to seekers of information.^[11]

The 1976 Government in the Sunshine Act amendments to the FOIA

In 1976, as part of the Government in the Sunshine Act, Exemption 3 of the FOIA was amended so that several exemptions were specified:

1) information relating to national defense, 2) related solely to internal personnel rules and practices, 3) related to accusing a person of a crime, 4) related to information where disclosure would constitute a breach of privacy, 5) related to investigatory records where the information would harm the proceedings, 6) related to information which would lead to financial speculation or endanger the stability of any financial institution, and 7) related to the agency's participation in legal proceedings.

The 1986 Omnibus Anti-Drug Abuse Act amendments to the FOIA

The FOIA amendments were a small part of the bipartisan Anti-Drug Abuse Act of 1986. Congress amended FOIA to address the fees charged by different categories of requesters and the scope of access to law enforcement and national security records. The amendments are not referenced in the congressional reports on the Act, so the floor statements provide an indication of Congressional intent.^[12]

President Reagan's Executive Order limiting the FOIA

Between 1982 and 1995, President Reagan's Executive Order 12,356 of 1982 allowed federal agencies to withhold enormous amounts of information under Exemption 1 (relating to national security information). ^[13] The outcry from the effect that the Reagan Order had on FOIA requests was a factor in leading President Clinton to dramatically alter the criteria in 1995.^[14]

Expansion of the FOIA during the Clinton Administration

Between 1995 and 1999, President Clinton issued executive directives (and amendments to the directives) that allowed the release of previously classified national security documents more than 25 years old and of historical interest, as part of the FOIA.^[15] This release of information allowed many previously publicly unknown details about the Cold War and other historical events to be discussed openly.^[14]

The Electronic Freedom of Information Act Amendments of 1996

The Electronic Freedom of Information Act Amendments of 1996 (E-FOIA) stated that all agencies are required by statute to make certain types of records, created by the agency on or after November 1, 1996, available electronically. Agencies must also provide electronic reading rooms for citizens to use to have access to records. Given the large volume of records and limited resources, the amendment also extended the agencies' required response time to FOIA requests. Formerly, the response time was ten days and the amendment extended it to twenty days.[1]

President Bush's Executive Order limiting the FOIA

Executive Order 13233, drafted by Alberto R. Gonzales and issued by President George W. Bush on November 1, 2001, shortly after the September 11, 2001 attacks, restricted access to the records of former Presidents.

President Obama's Executive Order encouraging open government

On January 21, 2009, President Barack Obama issued Executive Order 13489 that encourages openness, transparency and accountability in government records. This does not change the Presidential Records Act. It did, however, revoke Executive Order 13233 of November 1, 2001. ^[16]

The Intelligence Authorization Act of 2002 amending the FOIA

In 2002, Congress passed the Intelligence Authorization Act for Fiscal Year 2003, Public Law 107-306.^[17] Within this omnibus legislation were amendments to the FOIA (pertaining mainly to intelligence agencies) entitled "Prohibition on Compliance with Requests for Information Submitted by Foreign Governments":

Section 552(a)(3) of title 5, United States Code, is amended: (1) in subparagraph (A) by inserting "and except as provided in subparagraph (E)," after "of this subsection,"; and (2) by adding at the end the following: "(E) An agency, or part of an agency, that is an element of the intelligence community (as that term is defined in section 3(4) of the National Security Act of 1947 (50 U.S.C. 401a(4))) shall not make any record available under this paragraph to-- "(i) any government entity, other than a State, territory, commonwealth, or district of the United States, or any subdivision thereof; or "(ii) a representative of a government entity described in clause (i).".^[18]

In effect, this new language precluded any covered US intelligence agency from disclosing records in response to FOIA requests made by foreign governments or international governmental organizations. By its terms, it prohibits disclosure in response to requests made by such other-than-U.S. governmental entities either directly or through a "representative." ^[19] This means that for any FOIA request that by its nature appears as if it might have been made by or on behalf of a non-U.S. governmental entity, a covered agency may inquire into the particular circumstances of the requester in order to properly implement this new FOIA provision.^[17]

The agencies affected by this amendment are those that are part of, or contain "an element of," the "intelligence community." As defined in the National Security Act of 1947 (as amended), they consist of the Central Intelligence Agency, the National Security Agency, the Defense Intelligence Agency, the National Imagery and Mapping Agency, the National Reconnaissance Office (and certain other reconnaissance offices within the Department of Defense), the intelligence elements of the Army, the Navy, the Air Force, and the Marine Corps, the Federal Bureau of Investigation, the Department of the Treasury, the Department of Energy, and the Coast Guard, the Department of Homeland Security, the Bureau of Intelligence and Research in the Department of State, and "such other elements of any other department or agency as may be designated by the President, or designated jointly by the Director of Central Intelligence and the head of the department or agency concerned, as an element of the intelligence community." ^[17]^[20]

President Bush signs "OPEN Government Act of 2007" - December 31, 2007

establishing a definition of "a representative of the news media;" (2) directing that required attorney fees be paid from an agency's own appropriation rather than from the Judgment Fund; (3) prohibiting an agency from assessing certain fees if it fails to comply with FOIA deadlines; and (4) establishing an Office of Government Information Services in the National Archives and Records Administration to review agency compliance with FOIA.

The law recognizes electronic media specifically and defines "News Media" as "any person or entity that gathers information of potential interest to a segment of the public, uses its editorial skills to turn the raw materials into a distinct work, and distributes that work to an audience."

The law extends the 20 day deadline by allowing for up to 10 days between the FOIA office of the agency and the component of the agency holding the records and specifically allows for clarification of requests by the FOIA office (Effective 12/31/2007).

And call for each agency to designate a FOIA Public Liaison, "who shall assist in the resolution of any disputes" (Effective 12/31/2008).

Requires agencies to assign tracking numbers to FOIA requests that take longer than 10 days, and to provide systems determining the status of a request.

Modifies and defines annual reporting requirements for each agencies FOIA program.

Specifically addresses data sources used to generate reports; "shall make the raw statistical data used in its reports available electronically..."

Redefines the definition of an agency "record" to include information held for an agency by a government contractor.

The newly established Office of Government Information Services will offer mediation services to resolve disputes as non-exclusive alternative to litigation.

Requires agencies to make recommendations personnel matters related to FOIA such as whether FOIA performance should be used as a merit factor.

Requires agencies to specify the specific exemption for each deletion(redaction) in disclosed documents.

Notable cases

A major issue in released documentation is government "redaction" of certain passages deemed applicable to the Exemption section of the FOIA. Federal Bureau of Investigation (FBI) officers in charge of responding to FOIA requests "so heavily redacted the released records as to preclude needed research." ^[11] This has also brought into question just how one can verify that they have been given complete records in response to a request.

J. Edgar Hoover

This trend of unwillingness to release records was especially evident in the process of making public the FBI files on J. Edgar Hoover. Of the 164 files and about eighteen thousand pages collected by the FBI, two-thirds were withheld from Athan G. Theoharis and plaintiff, most notably one entire folder entitled the "White House Security Survey". Despite finding out that the Truman Library had an accessible file which documented all the reports of this folder, the FBI and Office of Information and Privacy it put forth "stony resistance" to the FOIA appeal process. (I–pg. 27) Some argue that it was not even this sixteen year series of three appeals to the Justice Department which gained a further opening of the files, but rather the case of U.S. Department of Justice v. Landano which spurred on a break in stolid FBI opposition.

Murder trial

A murder trial decided in the year of 1993, U.S. Department of Justice v. Landano, involved what was alleged to be a felony murder committed during a group burglary by defendant Landano. Justice Sandra Day O'Connor wrote the unanimous opinion. "In an effort to support his claim in subsequent state court proceedings that the prosecution violated Brady v. Maryland, 373 U.S. 83, by withholding material exculpatory evidence, he filed Freedom of Information Act (FOIA) requests with the FBI for information it had compiled in connection with the murder investigation." ^[21] In defense, the FBI put forth a claim that the redacted sections of the documents requested were withheld in accordance with FOIA regulations protecting the identity of informants who gave information regarding case details. However, O'Connor ruled that those who supplied information had no need to remain anonymous in the court setting. "To the extent that the Government's proof may compromise legitimate interests, the Government still can attempt to meet its burden with in camera affidavits." The court thus remanded the case to the Circuit Courts and rejected the FBI's claim of confidentiality as being a valid reason to withhold information.

"While most individual sources may expect confidentiality, the Government offers no explanation, other than administrative ease, why that expectation always should be presumed."^[21] Thus, when Theoharis and company were in the middle of fighting in court to obtain J. Edgar Hoover files, they may well have benefited from Landano and also Janet Reno's assertions of the government's need for "greater openness" and "discretionary releases" in 1993.

E-mail

In the case of Scott Armstrong et al. v. Executive Office of the President et al., the White House used the PROFS ^[11] computer communications software. With encryption designed for secure messaging, PROFS notes concerning the Iran-Contra affair (arms-for-hostages) under the Reagan Administration were insulated. However, they were also backed up and transferred to paper memos. The National Security Council, on the eve of President George H.W. Bush's inauguration, planned to destroy these records. The National Security Archive, Armstrong's association for the preservation of government historical documents, obtained an injunction in Federal District Court against the head, John Fawcett, of the National Archives and Records Administration and the National Security Council's purging of PROFS records. A Temporary Restraining Order was approved by Senior U.S. District Court Judge Barrington D. Parker. Suit was filed at District Court under Judge Richey, who upheld the injunction of PROFS records. [^[11] – pgs. 151-152]

Richey gave a further injunction to prevent a purging of the G.H.W. Bush administration records as well. On counts of leaving the White House clean for the new Clinton Administration, the Bush group appealed but was denied its request. Finally, the Clinton Administration appealed to the U.S. Court of Appeals, stating that the National Security Council was not truly an agency but a group of aides to the President and thus not subject to FOIA regulations. Under the Presidential Records Act, "FOIA requests for NSC [could] not be filed until five years after the president ha[d] left office… or twelve years if the records [were] classified." [^[11] – pg. 156] The Clinton administration won, and the National Security Archive was not granted a writ of certiorari by the Supreme Court on these grounds. According to Scott Armstrong, taking into account labor and material costs, the three presidential administrations spent almost $9.3 million on contesting the National Security Archive FOIA requests for PROFS e-mail records. (^[11] - pg. 159)

Barbara Schwarz

Wikisource has original text related to this article:

Civil Action 98-2406 (HHK), Schwarz v. United States Department of Treasury, et al.

Records at the United States Department of Justice (DOJ) show Barbara Schwarz, a citizen of Germany,^[22] has made more requests under the FOIA than any other person since it became law in 1966.^[22] For more than ten years Schwarz has made repeated requests with many federal departments and agencies for public records the government says don't exist.

Schwarz believes, and her requests are aimed to prove, that rather than having been born in Germany her actual birth was around 1956 inside a secret government submarine base called Chattanooga under the Great Salt Lake. She further believes herself to be daughter of Church of Scientology founder L. Ron Hubbard.^[22]^[23] Further saying that she was then kidnapped, taken to Germany, and given a false identity including a German birth certificate which was doctored to conceal her actual birth in Utah.^[22]

Working from her Salt Lake City, Utah home or a nearby library at least one of Schwarz's lawsuits has been considered by a U.S. District or U.S. Circuit Court of Appeals somewhere in the nation every year since 1993 and has filed unsuccessful appeals to the U.S. Supreme Court.^[22] One of her complaints to the U.S. District Court in Washington, D.C., set a record for voluminous litigation at 2,370 pages, naming 3,087 defendants, all of whom were employed as FOIA or "Privacy Act" officers in the federal government claiming their denials to be part of a conspiracy to keep the truth from her. U.S. District Court Judge John Bates said the FOIA's "admirable purpose is abused when misguided individuals are allowed (in this case repeatedly) to submit requests to every agency and subdivision of the government, seeking information about an imaginary conspiracy," in a ruling against her.^[22]

Schwarz has filed pro se litigation in the hopes of forcing these agencies to do more detailed searches and to waive the costs, claiming poverty, so far without success.^[22] The Justice Department has advised federal employees charged with responding to FOIA requests that until Schwarz satisfies outstanding search and copying fees incurred by previous filings, future requests may legally be denied.^[22]

References

^ Gidiere, Stephen, 2006. The Federal Information Manual (Chicago, IL: American Bar Association).
^ 5 USC Chapter 5 § 552 Retrieved on 2009-05-06
^ Branscomb, Anne (1994). Who Owns Information?: From Privacy To Public Access. Section 552 – (a)4(F): BasicBooks.
^ FOIA updates Vol XVII 4
^ ^a ^b ^c ^d ^e ^f ^g ^h ⁱ ACU Step-by-Step Guide to using the Freedom of Information Act; American Civil Liberties Union Foundation pamphlet written by Allan Robert Adler, pp. 3-5, ISBN 0-86566-062-X
^ ^a ^b "Freedom Of Information Act" (HTML). 5 U.S.C. § 552. U.S. Government Law. 2002. http://www.usdoj.gov/oip/foiastat.htm. Retrieved 2006-12-12.
^ "Veto Battle 30 Years Ago Set Freedom of Information Norms: Scalia, Rumsfeld, Cheney Opposed Open Government Bill; Congress Overrode President Ford's Veto of Court Review". Electronic Briefing Book No. 142. National Security Archive (George Washington University, Washington, D.C.). 2004-11-23. http://www.gwu.edu/~nsarchiv/NSAEBB/NSAEBB142/index.htm.
^ Memorandum for President Ford from Ken Cole, "H.R. 12471, Amendments to the Freedom of Information Act," September 25, 1974 Source: Gerald R. Ford Library. Document 10.
^ "Veto Battle 30 Years Ago Set Freedom of Information Norms"National Security archive. 2004.
^ Your Right to Federal Records: Questions and Answers on the Freedom of Information Act and the Privacy Act. Electronic Privacy Information Center. 1992. http://www.epic.org/open_gov/rights.html.
^ ^a ^b ^c ^d ^e ^f Theoharis, Athan (1998). A Culture of Secrecy: The Government Versus the People’s Right to Know. Kansas: University Press of Kansas. pp. 27.
^ "FOIA Reform Legislation Enacted: FOIA Update Vol. VII, No. 4". U.S. Department of Justice. 1986. http://www.usdoj.gov/oip/foia_updates/Vol_VII_4/page1.htm.
^ Exec. Order No. 12,356, 3 C.F.R. 166 (1983)
^ ^a ^b "Brief Amici Curiae of The Reporters Committee for Freedom of the Press and the Society of Professional Journalists in support of Leslie R. Weatherhead, Respondent" (HTML). United States of America, United States Department of Justice, and United States Department of State, Petitioners, v. Leslie R. Weatherhead, Respondent, in the Supreme Court of the United States. 1999-11-19. http://www.rcfp.org/news/documents/weatherhead.html#III.
^ "Freedom of Information Act (FOIA)" (HTML). Illinois Institute of Technology Paul V. Galvin Library. http://www.gl.iit.edu/govdocs/foia.html. Retrieved 2002-06-04.
^ http://www.gopusa.com/news/2009/march/0317_foia_requests1.shtml
^ ^a ^b ^c "FOIA Post: FOIA Amended by Intelligence Authorization Act". United States Department of Justice Office of Information and Privacy. 2002. http://www.usdoj.gov/oip/foiapost/2002foiapost38.htm.
^ Pub. L. No. 107-306, 116 Stat. 2383, § 312 (to be codified at 5 U.S.C. § 552(a)(3)(A), (E)).
^ 5 U.S.C. § 552(a)(3)(E)(ii) (as amended)
^ 50 U.S.C. § 401a(4) (2000)
^ ^a ^b Cornell Law School Resources (2006-05-24). "United States Dep't of Justice v. Landano (91-2054), 508 U.S. 165 (1993)" (HTML). http://supct.law.cornell.edu/supct/html/91-2054.ZS.html. Retrieved 2006-12-12.
^ ^a ^b ^c ^d ^e ^f ^g ^h Smith, Christopher (May 13, 2003), S.L. Woman's Quest Strains Public Records System, The Salt Lake Tribune, http://www.cs.cmu.edu/~dst/Secrets/barbara_schwarz.html, retrieved 2007-12-24 .
^ Woman pursues Oregon public records - lots of them, Associated Press, USA Hosted by: www.religionnewsblog.com, May 3, 2004, http://www.religionnewsblog.com/7089/woman-pursues-oregon-public-records-lots-of-them, retrieved 2007-12-24 .

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