The Washington Post Company v. United States Department of State, the Washington Post Company v. United States Department of State

In this Freedom of Information Act proceeding the Washington Post seeks Department of State records that would indicate whether two individuals now residing in Iran are U.S. citizens or hold U.S. passports. The Department withheld the records, claiming that they were exempt from disclosure under 5 U.S.C. § 552(b)(6) (1976). That provision protects “personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy.” On cross-motions for summary judgment, the district court ordered disclosure of the records. The Department…