Exemption 6


 * This article is part of a series on Exemptions

Introduction
Exemption 6 generally applies to records that involve personal privacy. It incorporates a balancing test that weighs any privacy interest against the public interest in disclosure.

Text of Exemption 6
(b) This section does not apply to matters that are—[...]


 * (6) personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;

Threshold Requirement: "Personnel and Medical Files and Similar Files"
In interpreting the scope of “personnel,” the U.S. Supreme Court has explained that while “[t]here is sparse legislative history as to the precise scope” of the term, Congress envisioned that files maintained by agencies such as the Health, Education, and Welfare Department, Selective Service, and Veterans’ Administration constituted “personnel files.” The Court held that case summaries of honor code hearings of the U.S. Air Force Academy were not “personnel files” because they did not contain personal data ordinarily found in a personnel file, such as birthplace, parents’ names, past residences, school records, examination results, or work performance evaluations. Further, access to the files was “not drastically limited, as is customarily true of personnel files.” Instead, the court characterized them as “similar files” because they related to personnel discipline and “implicate[d] similar privacy values” as personnel files, such as the possibility of embarrassment, disgrace, and loss of friends or work. However, the Court also emphasized that even where a “personnel file” is at issue, an agency cannot apply a blanket exemption to withhold all of the information contained in such a file, and must release it unless “a clearly unwarranted invasion of privacy” would result.

The U.S. Supreme Court has held that the term “similar files” has “a broad, rather than a narrow, meaning,” citing the legislative history of the FOIA. An example of a record that a court found to be a “similar file[]” was an agency investigative report containing information about individuals’ “marital status, legitimacy of children, identity of fathers of children, medical condition, welfare payments, alcoholic consumption, family fights, [and] reputation.”

If a record meets the threshold requirement, agencies and courts balance the individual's privacy interest against the public interest in disclosure.

Nature of Privacy Interest/Harm
A privacy interest is cognizable under FOIA where it is “substantial;” however, in the FOIA context, courts have found that a “substantial” privacy interest is any interest greater than one that is de minimis, or insignificant. A “substantial” privacy interest will be more likely found if disclosure of the information would potentially lead to some form of embarrassment or retaliation.

Determining the level of privacy interest in the information often requires looking to the particular facts of each case. As one court found: “‘the statute does not categorically exempt individuals’ identities. . . because the ‘privacy interest at stake may vary depending on the context in which it is asserted.’” In a case involving the release of lists of names or other personally identifying information, for example, the U.S. Supreme Court has emphasized that the question of whether disclosure “is a ‘significant or a de minimis threat depends upon the characteristic(s) revealed by virtue of being on the particular list, and the consequences likely to ensue.”

A “clearly unwarranted invasion of personal privacy,” requires more than simply stating “a demonstrated privacy interest.”

The U.S. Supreme Court has clarified that the exemption is “directed at threats to privacy more palpable than mere possibilities,” and the U.S. Court of Appeals for the D.C. Circuit requires the government to show a “substantial probability that the disclosure will lead to the threatened invasion.”

For example, a court held that the Department of the Navy did not meet this standard in attempting to withhold the names and amounts of prescription drugs that the National Naval Medical Center provided to the Office of Attending Physician to the U.S. Congress. The court explained that “courts ‘may properly discount [the] probability’ of invasion of privacy in light of attendant circumstances,’” and, in this case, even if each of the drugs was prescribable only for one disease, “it is fanciful to assume that without more. . . the knowledge that someone among 600 possible recipients was probably using the drug. . . would lead to the conclusion that Beneficiary X has disease Y.”

However, courts have recognized a greater privacy interest where disclosure of the information would put identified individuals in danger of embarrassment or unwanted intrusions. For example, the U.S. Supreme Court found a significant privacy interest in the names of Haitian nationals who unsuccessfully attempted to emigrate to the U.S. and were interviewed after being sent back to Haiti. The Court explained that release would identify them as people who cooperated with a federal investigation of Haiti’s compliance with its promise not to prosecute certain returnees, and could subject them to “retaliatory action” and embarrass them, and their families, “in their social and community relationships.”

Likewise, the U.S. Supreme Court recognized “some nontrivial privacy interest in nondisclosure” of the home addresses of non-union employees, recognizing their interest “in avoiding the influx of union-related mail, and, perhaps, union-related telephone calls or visits, that would follow disclosure.”

Examples of Substantial/De Minimis Privacy Interests
Instances where courts have recognized a privacy interest under FOIA include:
 * An FBI Special Agent’s name and an FBI support employee’s name and phone number, where releasing that information could subject them to harassment
 * Naval hospital admission records, as the patients had a “substantial privacy interest in avoiding disclosure of the fact that they sought medical treatment.”
 * The type and date of vaccines administered to individuals or their legal representatives contained in petitions filed against the Department of Health and Human Services and alleging death or injury from the vaccines, as this information could be linked to the individuals’ identities by comparison to other information.
 * The total amount of Medicare payments received by physicians for covered services.
 * Identities and home addresses of consumers who submitted complaints to the Federal Trade Commission regarding false charges that appeared on their credit card bills, as the court recognized consumers’ interest in keeping this information free from release to the general public.

In contrast, courts have not recognized a substantial privacy interest under FOIA in the following information:
 * The names of U.S. Postal Service employees involved in responding to allegations of an identity theft situation involving USPS employees, as the government failed to show that the employees would be harassed or intimidated following their disclosure.
 * The names and business addresses of unsuccessful applicants for federal research grants, as “[t]he adverse effect of a rejection of a grant proposal, if it exists at all, is limited to the professional rather than personal qualities of the applicant,” the government did not put forth strong evidence of stigma associated with the release of the information, and because “federal grant applicants cannot reasonably expect that their efforts to secure government funds, especially in a field so much in the public eye as cancer research, will remain purely private matters.”
 * Identifying information in letters sent by members of the public to the IRS inquiring about audits and investigations of 501(c)(3) tax-exempt organizations, as there is no “blanket anonymity for private citizens who write letters requesting assistance from government officials, even when personal relationships are implicated” and the agency offered no facts to support its assertion that the individuals would be harassed.
 * The name of a corporation that paid a member of a federal advisory committee to serve on the corporation’s board, as the court found that a person’s employment history does not generally have a high privacy interest.

Media Contact as Potential Harm
Courts have frequently held that the fact that disclosure of records may result in news media contact with the related individuals is “not the sort of invasion of privacy envisioned by Exemption 6.” Rather, as one court found, the privacy invasion must result from “the very ‘production’ of the documents.” That is, the degree of the privacy interest implicated by potential media contact with individuals identified in the records is based “on the nature of the information sought and not on the identity of the seeker.”

For example, the U.S. District Court for the District of Columbia found that the release of a list containing “generic” information about farmers receiving cotton subsidies, including their names, farm addresses, how much cotton they grew, and the amount of subsidies they received, would not “invite the kind of unwarranted intrusions that would justify nondisclosure.” This information was not “stigmatizing, embarrassing or dangerous.”

The court emphasized that “the release of the information itself — the fact that a particular farmer received a cotton subsidy. . . must create the unwarranted invasion of personal privacy and not the fact that it is The Washington Post that happens to be asking for it.” Further, it explained that “the mere threat of media attention does not suffice to draw the protective cloak of Exemption 6 over information that happens to be newsworthy.”

In contrast, where the subject of the information sought is only incidentally connected to a high-profile criminal matter, unwanted media contact may provide the basis for a stronger privacy interest. For example, the U.S. Court of Appeals for the Ninth Circuit ruled that witnesses and FBI agents connected to the investigation of a widely publicized plane crash had a privacy interest in avoiding outside contacts, such as from the media or commercial solicitors, that outweighed the public interest in their release under Exemption 7(C). The court emphasized that the privacy interests were heightened because the parties were involved with “a controversial criminal investigation,” and explained that “the privacy interests of citizens are highest when disclosure would reveal information collected about them in conjunction with a criminal inquiry.” The court specified that this was especially the case “where their link to the investigation is the result of ‘mere happenstance.’”

Private Party Attempting to Influence Policy
One factor that may minimize any privacy interest argument is where the information relates to a private party’s attempt to affect government policy, as courts have often recognized a diminished privacy interest in such cases.

As noted by the U.S. Court of Appeals for the Ninth Circuit, “the few cases considering a private party attempting to influence government policy typically find in favor of disclosure, lacking countervailing concerns.” A U.S. District Court for the District of Columbia has also affirmed that “[w]hen a citizen petitions his government to take some action, courts have generally declined to find the identity of the citizen to be information that raises privacy concerns under Exemption 6.”

For example, a court found that the public interest in release outweighed any privacy interests in the names of those who submitted unsolicited comments to an agency regarding proposed changes in a video shown at the Lincoln Memorial, as disclosing “who voluntarily submitted comments” for “a proposed policy decision” did not implicate “the kind of privacy concerns protected by Exemption 6.”

In another case, a court found it “remarkable” that the government objected to the release of the names and addresses of those who submitted public comments during an agency’s rulemaking process where only one of the 24,000 people who submitted comments requested anonymity, and the agency’s notice of proposed rulemaking itself “made no reference to any limitations on the public's ability to review the comments submitted.” The court held that there was little privacy interest — “if any” — in the nondisclosure of that information.

Promises of Confidentiality
Promises of confidentiality by the government “can not, in and of themselves, override” the FOIA’s disclosure mandates, and “[i]t will obviously not be enough for the agency to assert simply that it received the file under a pledge of confidentiality to the one who supplied it.”

The circumstances related to a particular promise are important to consider. For example, a court held that while agency consultants had a “heightened” expectation of privacy in their conflict-of-interest statements because of a clause stating the information would not be disclosed except “for good cause,” this “vague phrase” did not “substantially increase” most of the consultants’ privacy expectations because it could potentially be interpreted to mean that the information would “generally be made public.”

In contrast, the U.S. Supreme Court held that assurances of confidentiality given to Haitian nationals had “special significance” in assessing the privacy interest in summaries of interviews with them containing their names. The Court explained that the interviewees may have been willing to discuss more private matters in light of that assurance, as the release of the information might risk their mistreatment due to the nature of what they discussed.

The public interest in the release of records is another factor to be considered. As one court has held, “Other things being equal, release of information provided under a pledge of confidentiality involves a greater invasion of privacy than release of information provided without such a pledge,” but “such a pledge should not be given determinative weight where the public interest in disclosure is high and the privacy interest in the information would otherwise be low.”

Personal Privacy for Business Entities and Information
The government may only assert a personal privacy interest for individuals, as “corporations, businesses and partnerships have no privacy interest whatsoever under Exemption 6.” The U.S. Supreme Court has reiterated this point in the context of an Exemption 7(C) case. However, individuals employed by a corporation may claim such a personal right.

Further, even with respect to individuals, Exemption 6 only “protect[s] intimate details of personal and family life, not business judgments and relationships,” For example, one court ruled that Exemption 6 does not “shield matters of such clear public concern as the names of those entering into contracts with the federal government.”

In another case, the U.S. District Court for the District of Columbia held that the “defining characteristic” of a list containing “relatively generic facts — names, business addresses and amounts of subsidy” received from the government was that it “contains business addresses” of individuals “who have sought and received government subsidies in their business capacities.” Even though the business and home addresses could be the same in some cases, the court found no privacy interests that would justify withholding because the farmers “did not get subsidies because they live on a farm but because they work on one,” and so the privacy interest “must be measured in light of the effect on the recipients as businesspeople.”

One exception to the general rule regarding business records is that the exemption “applies to financial information in business records when the business is individually owned or closely held, and ‘the records would necessarily reveal at least a portion of the owner’s personal finances.’”

Where a requester sought files in which 98 percent of the farms represented were either “family owned” or owned by “small family farmers,” a court held that information about their crops fell within the scope of Exemption 6, as revealing this information “would necessarily reveal at least a portion of the owner’s personal finances,” and the requester “ha[d] not shown that all farms are owned in such a manner that disclosing their assets will in no instances allow the public to trace the information to individual farmers.”

In another case, however, a court found that individuals who obtained permits to graze livestock on federal lands in their “citizen” — rather than a business — capacity had a “minimal” privacy interest in their names and personal home addresses, while permit holders comprising closely held and family owned entities had “an even smaller privacy interest” in the release of their addresses. While the parties opposing release claimed that this information could be used in conjunction with other publicly available information, such as herd size, to reveal some of their personal finances, the court rejected this argument because that they did not “demonstrate[] how or how often” such “inferences might occur” or “how specific these inferences could be” in light of “unknown variables and other factors regarding the correlation between size of herd and personal financial wealth.” The court in that case also found any privacy interest further minimized by the fact that the requested information was a list of “generic” information about many individuals — nearly 18,000 permit holders — thereby reducing each named individual’s privacy interest.

Release Would Benefit Subject of Records
The fact that release of the information would benefit the individuals with an alleged privacy interest may arguably minimize that interest.

For example, where a requester sought disclosure of the names of people with unclaimed deposits at banks under receivership with the Federal Deposit Insurance Corporation, the U.S. Court of Appeals for the D.C. Circuit stated that the list could — with some safeguards – be released, and that “the FOIA analysis under Exemption 6 must include consideration of any interest the individual might have in the release of the information, particularly when the individuals who are ‘protected’ under this exemption are likely unaware of the information that could benefit them.”

Information Already in Public Domain
As a general matter, “[o]ne can have no privacy interest in information that is already in the public domain, especially when the person asserting his privacy is himself responsible for placing that information into the public domain.” Where you have proof that the information sought is already in the public domain, you should argue this point and provide any supporting documentation.

Compilations of public information may receive heightened privacy rights under the doctrine of “practical obscurity.” In one case, the U.S. Supreme Court applied this doctrine to rule that while the information at issue was comprised of publicly available information — criminal “rap sheets” containing individuals’ complete histories of arrests, charges, convictions, and imprisonment — the subjects had a recognizable privacy interest in their collection into FBI rap sheets. The Court emphasized “the distinction, in terms of personal privacy, between scattered disclosure of the bits of information contained in a rap sheet and revelation of the rap sheet as a whole,” and recognized a privacy right in the latter because it was not “freely available.”

However, in a more recent case, the U.S. District Court for the District of Columbia held that releasing a comprehensive list of docket numbers, courts, and case names in which defendants were subject to warrantless cell phone tracking — and were convicted or entered guilty pleas — would not compromise much more than a de minimis privacy interest, where the information on the lists contained little personal information that was “readily accessible” through “publicly available computerized databases” and did not pertain to those acquitted or not the focus of public attention, such as uncharged witnesses.

Diminished Privacy Rights for Public Figure/Official
Another factor that may “significantly diminish[]” the privacy interest is a subject’s public figure or public official status. “[P]ersons who have placed themselves in the public light, e.g., through politics, or voluntarily participate in the public arena have a significantly diminished privacy interest than others.”

For example, a court held that a person “closely associated with” former U.S. President Ronald Reagan had a “significantly diminished” privacy interest in information about his 40 year-old traffic violations because he was a public figure. The court noted that this person had written memoirs, hosted a radio show for decades, was described on his website as “a popular national speaker on issues related to conservative politics, adoption, and the life lessons,” and garnered press attention through his views on the Republication nomination process and campaign efforts for a presidential candidate.

If the information sought relates to a government employee, their “privacy interests may be diminished in cases where information sought under FOIA would likely disclose ‘official misconduct.’”

However, “the level of responsibility held by a federal employee, as well as the activity for which such an employee has been censured, are appropriate considerations for determining the extent of the public's interest in knowing the identity of that censured employee.” That is, courts accord lower level officials a greater level of personal privacy interest than they do more senior officials.

On this basis, the U.S. Court of Appeals for the Ninth Circuit held that employees identified in a Forest Service accident report about the agency’s response to a fire were not stripped of their privacy interests even where some of them were disciplined in connection with the investigation, as none were “accused of official misconduct” and the employees were “low and mid-level.”

In contrast, where a requester sought the attendance and sick leave records for an assistant bureau chief for the Federal Communications Commission in an attempt to substantiate allegations that the individual had improperly used sick leave, a court held the assistant held “a position of relative influence and [was] not a low-level government official deserving of a heightened level of privacy.”

The U.S. Court of Appeals for the District of Columbia Circuit addressed this issue in evaluating an agency’s reliance on Exemptions 6 and 7(C) in refusing to deny or confirm the existence of records containing evidence of misconduct by two Drug Enforcement Administration special agents. The court explained that “[t]he public’s interest in disclosure of personnel files derives from the purpose of the [FOIA] – the preservation of ‘the citizens’ right to be informed about what their government is up to.’” While the requester in that case argued that his allegations that the agents committed unethical and fraudulent acts in obtaining his conviction provided an overriding public interest, the court disagreed. It ruled that “[t]he identity of one or two individual relatively low-level government wrongdoers, released in isolation, does not provide information about the agency’s own conduct.” The court pointed out that there was “no evidence, let alone any public knowledge, that wrongdoing has occurred.”

In contrast, a court held that an agency properly released a reprimand issued to an Air Force major for his involvement in a friendly-fire incident even though “he was not a senior military official, but rather. . . the junior officer” at the time of the incident, as there was demonstrated international interest in the incident. The court ruled that the public interest was served by the release of the information because it “gave the public. . . insight into the way in which the United States government was holding its pilot accountable.”

Individual Identified is Deceased
The privacy interest in identifying information may be further diminished where the individual identified in the record is deceased. The government must make “a reasonable effort to ascertain life status,” and those efforts “must be assessed in light of the accessibility of the relevant information.” However, in the context of an Exemption 7(C) privacy case, the U.S. Supreme Court has recognized “surviving family members’ right to personal privacy with respect to their close relative’s death-scene images.”

Public Interest
Under the balancing text incorporated into Exemption 6, even if disclosure of a record implicates personal privacy it can be outweighed by the public interest in disclosure.

Proper Type of Public Interest
Not every “public interest” will be deemed important by a court or agency. Courts weigh the privacy interest “against the only relevant public interest in the FOIA balancing analysis — the extent to which disclosure of the information sought would ‘she[d] light on an agency's performance of its statutory duties’ or otherwise let citizens know ‘what their government is up to.’” This is often referred to as the “central purpose” requirement, as the FOIA’s core purpose is said to be to open government operations to public review.

For example, the U.S. Court of Appeals for the Ninth Circuit held that the public interest in the identities of telecommunications industry lobbyists who were tied to efforts to reduce or eliminate the liability of their clients from the government’s warrantless wiretapping activities outweighed their privacy interests, as the information could be used “to determine how the Executive Branch used advice from particular individuals and corporations in reaching its own policy decisions,” including “decisions potentially shielding firms lobbying (and donating to campaigns) from nine-figure liabilities.”

Likewise, the U.S. District Court for the District of Columbia found it “difficult to understand how there could not be a substantial public interest in disclosure of documents regarding the manner in which [the Department of Justice] handled high profile allegations of public corruption about an elected official.” In that case, the court found a significant public interest in records relating to the agency’s investigation of a member of the U.S. House of Representative on allegations of bribery and other illegal behavior where legislation had been passed specifically directing the Justice Department to investigate those claims. Further enhancing the public interest, “highly unusual, and unexplained” changes had been made in the language of the relevant appropriations bill that was a subject of the investigation, and the legislator at issue had made statements about the investigation on the floor of the House of Representatives.

In contrast, the U.S. Supreme Court found the public interest in the release of addresses of non-union employees to be “negligible, at best,” even though the unions seeking them might be able to use them “to communicate more effectively with employees.” Such disclosure “would not appreciably further” public knowledge of agency action, and “would reveal little or nothing about the employing agencies or their activities,” the Court ruled.

Government Misconduct
The public interest is particularly high where government misconduct is concerned and (mirroring the way privacy interests are assessed for government employees) “[t]he public interest in learning of a government employee’s misconduct increases as one moves up an agency’s hierarchical ladder.”

For example, the U.S. Court of Appeals for the Second Circuit found a strong public interest in release of information about an agency’s general counsel who was investigated for allegedly giving preferential treatment to former agency officials with financial interests in certain investment firms, as he was a high-ranking government employee facing serious allegations. In contrast, a court held that an agency properly withheld identifying information for low-level employees who had engaged in misconduct, as release of their names “would shed little light on the operation of government.”

In addition, in alleging misconduct, a requester must “produce evidence that would warrant a belief by a reasonable person that the alleged Government impropriety might have occurred.” Where a requester made “vague allegations of ‘fabricated’ charges. . . ‘illegal and conspiratorial conduct’. . . non-specific reference to ‘corrupt acts and practices of federal employees,’ and. . . implied suspicions as to the qualifications of the disciplinary hearing officer,” a court held that such naked allegations did “not rise to the level required.” In contrast, where the requester “identified allegations of fraud and conflict of interest, supported by government reports,” agency investigations, and news articles, a court found a higher interest in public disclosure.

Derivative Use Theory
A requester can also argue that “derivative uses” for the information increase their public interest. That is, that the public interest in release of the information lies in others’ ability to use it to obtain additional information elsewhere, rather than in the information actually requested.

The U.S. Supreme Court has declined to “address the question whether a ‘derivative use’ theory would ever justify release of information about private individuals.” Under the theory, the value of the information arises from its usefulness in obtaining additional information, such as possible sources for interviews, rather than in the release of the information itself.

However, following the U.S. Supreme Court decision in U.S. Department of State v. Ray, some lower courts have factored in derivative uses in considering the public interest at stake. For example, a court upheld the release of the names, home addresses, and wage information of employees where it would assist a union in monitoring “whether the government is properly enforcing” a federal wage law, and the union had no alternative way of obtaining that information.

In contrast, a court rejected a requester’s reliance on the derivative use theory in seeking the names of firefighters to contact them and verify the statements in an accident report, since the court was “not persuaded that direct contact with employees would produce any information that has not already been revealed to the public through the four investigations that have already occurred and the three reports that have been publicly released.”

Examples of Sufficient/Insufficient Public Interest
Examples where courts have found a public interest sufficient to override a privacy interest under FOIA include:
 * The addresses, but not the names, of those who received disaster assistance payments from FEMA following hurricanes, as the public’s interest in evaluating how FEMA handled disaster relief claims and the requesters’ evidence that the agency may have engaged in “fraud, waste, or abuse” outweighed any privacy interests. The requesters explained that they would cross-reference the path of the disasters with the addresses where FEMA money was disbursed in order to identify any “outlier” homes that may have improperly received FEMA aid.
 * The identification numbers of U.S. Occupational Health & Safety Administration employees who underwent beryllium testing, as the public interest in assisting research concerning the agency’s response to beryllium sensitization among its employees outweighed any invasion of privacy in the release of the numbers, which — while originally consisting of the last four digits of the employees’ social security numbers — could be replaced with new numbers that had since been adopted by the agency.
 * A government employee’s self-assessment of his performance, officials’ recommendations and ratings on his performance, and a final decision and justification for his rating, where he was of high rank (“the de facto third in command” within the department), the requester alleged and provided some evidence of the employee acting in a way that exceeded his authority, and the public’s interest in assessing his government activity outweighed the employee’s privacy rights in that information.
 * The names of unsuccessful applicants for presidential pardons, where the court found such information did not reveal the type of sensitive information that would result in a clearly unwarranted invasion of privacy, the applicant was petitioning the government to perform a public act, and any privacy right was outweighed by the interest in allowing the public to compare successful and unsuccessful pardon applicants to understand the government’s decision making.
 * Voting lists containing the names and addresses of employees and marks identifying those who voted at an NLRB-sponsored union election, where the agency’s “assertion that the disclosure . . . will chill future voting” was “purely speculative, completely unsupported, and highly improbable,” and the public interest in allowing the requester to investigate potential voter fraud and corruption outweighed the privacy interests.

In contrast, courts have found that the stated public interests were not sufficient under FOIA to override a privacy interest in the following information:
 * The phone numbers called — or from which calls were received — by the Secretary and Deputy Solicitor of the Department of Labor, where the requester sought the information to “ferret[] out ‘undue influence’ on the agency by labor organizations. But the records sought included calls to private persons as well and so it was “not at all clear that disclosure of these phone numbers would actually advance this rarefied interest in this particular case.”
 * Construction workers’ payroll records — containing their names, addresses, and wage information — where the requester sought them in examining the government’s enforcement of a federal law governing wages on publicly funded projects, as disclosure of this list “would be of interest to people interested in marketing goods and services to people working in the construction trades,” and could lead to its use by marketers.
 * The personal e-mail addresses of those who were considered for but not selected for a human rights non-profit board, as release of such information “would not reveal ‘what the government is up to.’”
 * The names of federal employees who received hurricane assistance payments, as release of this information would “not reveal anything about the conduct of the [agency] or any official,” and the agency had already disclosed the amounts given and the factual bases for the amounts.
 * The names and addresses of people who submitted auto safety complaints to the National Highway Traffic Safety Administration, as the requester’s interest in contacting the complainants in its efforts to encourage auto safety was outweighed by the complainants’ privacy interest in avoiding junk mail, phone calls, “commercial exploitation,” or the potential release of information about injuries.

Strategies for challenging Exemption 6 withholdings

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