In Department of Air Force v. Rose (425 U.S. 352 (1976)), Rose was an Air Force
officer in law school. He was writing an article about the military academies
and filed a Freedom of Information Act (FOIA) request for
information about disciplinary actions against individual cadets. The Air
Force claimed that they were exempt under FOIA §552(b)(2) and §552(b)(6), because the documents were internal personal files that "held no
interest to the general public." The US Supreme Court ordered the
The US Supreme Court looked at
the legislative history of §552(b)(2)
("internal personnel rules and files") and found that there was
a legitimate public interest in knowing about cadet discipline, since
public tax dollars funded the school.
The Court found that §552(b)(2) is really only designed to protect very
trivial minutia from being requested (due to administrative burdens in
collecting the information).
The Court looked to §552(b)(6) ("personnel/medical and other files the
disclosure of which would violate personal privacy") and found that
it meant Agencies had to reasonably separate personal information from
non-protected information (by redacting the names and identifying info),
and then still release what remained.