Church of Scientology of California v. United States Postal Service

Church of Scientology (the Church) appeals from the district court’s refusal to order the United States Postal Service to comply with the Church’s Freedom of Information Act (FOIA) request. The district court decision came after this court remanded the case for consideration of the effect of the 1976 FOIA amendments on the Postal Service’s claimed exemption. The Church contends that the FOIA fully applies to the Postal Service and that the Postal Reorganization Act’s investigatory files exemption, 39 U.S.C. § 410 (c)(6), is not an exempting statute within the meaning of the amended FOIA, 5 U.S.C. § 552 (b)(3). We agree, and reverse the judgment of the district court.

I.

Facts

The Postal Reorganization Act, 39 U.S.C. §§ 101-5604 , extended the reach of the FOIA to the newly created Postal Service. In accordance with the FOIA, 5 U.S.C. § 552 (a)(3), the Church sought to obtain any records in possession of the Postal Service that concerned the Church. The Postal Service released numerous documents to the Church, but withheld certain materials, compiled during its investigations of possible criminal offenses.

Unconvinced that the documents were properly withheld, the Church…