Hulstein v. Drug Enforcement Admin., No. 11-2039 (8th Cir. 2012)
Annotate this CasePlaintiff brought suit under the Freedom of Information Act (FOIA), 5 U.S.C. 552, against the DEA seeking unredacted versions of two DEA reports. Plaintiff sought records of the DEA's investigation of him for drug activities. The DEA appealed the district court's order partially granting summary judgment in favor of plaintiff. The court reversed the district court's ruling for disclosure of the "Details" section of the 1990 report at issue and concluded that the redaction was appropriate under exemption 7(D) because there was an implied assurance of confidentiality under that exemption. The court also reversed the district court's ruling related to paragraph 7 of the 2008 report where the withheld information could be used to identify a private individual and triggered privacy concerns.
Court Description: Civil Case - Freedom of Information Act. District court's order of disclosure of details of DEA report of information provided by confidential informant who had assurance of confidentiality is reversed, as there was an implied assurance of confidentiality under exemption 7(D). Disclosure of names and signatures of law enforcement personnel is protected under exemption 7(C) because privacy interest outweighed public interest in disclosure.
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