Christopher Shelton Hunt v. Federal Bureau of Investigation

Christopher Shelton Hunt, incarcerated in federal prison, filed a request under the Freedom of Information Act, 5 U.S.C. § 552 (1988), seeking disclosure of a file containing the findings of an investigation into the conduct of a particular FBI agent. The investigation of the agent had been triggered by Hunt’s complaint that the female FBI agent in question, who had been assigned to his case while he was cooperating as a government witness, induced him to waive his right to counsel and accept an unwise plea bargain. After Hunt exhausted administrative procedures, the district court ordered the FBI to disclose the file in a redacted form, and the FBI now appeals. Because the redaction ordered would not adequately protect important privacy interests, and disclosure would not advance any significant public interest, we reverse.

The background is as follows. Hunt had originally filed a formal complaint in December of 1988 reporting the agent’s alleged conduct to the FBI’s Office of Professional Responsibility. The complaint prompted an internal investigation by the FBI. The Office of Professional Responsibility, however, failed to respond to Hunt’s repeated inquiries about the…