Cameranesi v. United States Department of Defense

The Department of Defense has shown that the Western Hemisphere Institute for Security Cooperation’s foreign students and instructors have a non-trivial privacy interest in keeping their identities secret. Disclosing their n§mes to the public would reveal their affiliation with the Institute, which might expose them to the risk of harassment or violence when they return to their home countries. But the question remains under Exemption 6 of the Freedom of Information Act (FOIA) whether that invasion of privacy would be “clearly unwarranted.” 5 U.S.C. § 552(b)(6). To answer that question, we…