Higgs v. U.S. Park Police

Dist. Ct. erred in granting plaintiff-death row prisoner’s claim under Freedom of Information Act, seeking copy of every document pertaining to his homicide convictions, where plaintiff asserted that defendant could not rely on Exemption 7(C) to redact all personal information, including names and contact information of individuals named in said documents, including reports of interviews, fingerprints and rap sheets of third-parties. Ct. of Appeals found that privacy interests of affected persons contained in said documents outweighed public interest in disclosure of redacted information, where: (1) plaintiff failed to present evidence that would warrant belief by reasonable person that redacted information would uncover govt. impropriety; and (2) prisoner’s interest in attacking his own conviction via FOIA request was not “public interest” sufficient to allow plaintiff’s challenge concerning defendant’s invocation of Exemption 7(C) to go forward.