CHRYSLER CORPORATION V. BROWN 441 U.S. 281 (1979) CASE BRIEF

CHRYSLER CORPORATION V. BROWN

441 U.S. 281 (1979)

NATURE OF THE CASE: This was a dispute over an injunction against agency disclosure under the FOIA and 18 U.S.C. 1905.

FACTS: The Chrysler Corp. (P) sought to enjoin agency disclosure on the grounds that it is inconsistent with the FOIA and 18 U.S.C. 1905, a criminal statute with origins in the 19th century that proscribes disclosure of certain classes of business and personal information. As a government contractor, P is required to comply with Executive Orders 1146 and 11375, which charge the Secretary of Labor with ensuring that corporations that benefit from Government contracts provide equal employment opportunity regardless of race or sex. P made lots of reports. The Defense Logistics Agency (D) notified P that it was going to disclose the information. Regulations promulgated by the Secretary of Labor provided for public disclosure of information from records of the OFCCP and its compliance agencies over and above that under the FOIA. It is the voluntary disclosure contemplated by these regulations, over and above that mandated by the FOIA, which is the gravamen of P's complaint in this case. On the day the documents were to be released, P filed a complaint. The District Court granted a temporary restraining order. P argued that disclosure was barred by the FOIA; that it was inconsistent with 18 U.S.C. 1905, 42 U.S.C. 2000e-8(e), and 44 U.S.C. 350, which, for ease of reference, will be referred to as the 'confidentiality statutes'; and finally that disclosure was an abuse of agency discretion insofar as it conflicted with OFCCP rules. The District Court held that certain of the requested information, the 'manning' tables, fell within Exemption 4 of the FOIA. The District Court read 1905 as not merely a prohibition of unauthorized disclosure of sensitive information by Government employees, but as a restriction on official agency actions taken pursuant to promulgated regulations. Both sides appealed, and the Court of Appeals for the Third Circuit vacated the District Court's judgment. The Supreme Court granted certiorari.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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