Baker v. Federal Bureau of Investigation

Dist. Ct. did not err in granting defendant-FBI’s motion for summary judgment in plaintiff’s action under Freedom of Information Act seeking un-redacted records of FBI investigation that resulted in criminal prosecution of one state police officer, who pleaded guilty to theft charge. While plaintiff sought names of FBI agents involved in investigation, as well as names of state police officers who assisted FBI and names of state police officers who were investigated but charged with any crime, defendant could properly invoke exemption to preclude disclosure of “personnel and medical files” that would constitute unwarranted invasion of personal privacy, since: (1) said disclosure could endanger FBI and state police officers by identifying them to gangsters still involved in criminal activities at issue in investigation; and (2) disclosure of investigated officers who were not charged with any crime would unfairly stigmatize them. Ct. rejected plaintiff’s claim that full disclosure of all officers involved in investigation would enable public to determine whether FBI had adequately staffed investigation.