Gannett Satellite Information Network, LLC v. U.S. Department of Justice

CourtDistrict Court, District of Columbia
DecidedMarch 29, 2023
DocketCivil Action No. 2022-0475
StatusPublished

This text of Gannett Satellite Information Network, LLC v. U.S. Department of Justice (Gannett Satellite Information Network, LLC v. U.S. Department of Justice) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gannett Satellite Information Network, LLC v. U.S. Department of Justice, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

GANNETT SATELLITE INFORMATION NETWORK, LLC,

Plaintiff, Civil Action No. 22-cv-475 (BAH)

v. Judge Beryl A. Howell

U.S. DEPARTMENT OF JUSTICE,

Defendant.

MEMORANDUM OPINION

Plaintiff Gannett Satellite Information Network, d/b/a USA Today, filed this lawsuit

against the U.S. Department of Justice (“DOJ”) challenging the agency’s response to plaintiff’s

request, pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, for data

regarding “individual-level information on the deaths of incarcerated people in the custody of

local jails, state prisons, and the Federal Bureau of Prisons,” Pl.’s Mem. in Supp. of Cross-Mot.

for Summ. J. & Opp’n to Def.’s Mot. for Summ. J. (“Pl.’s Mem.”) at 1, ECF No. 13-1, which

data is collected by a DOJ component in compliance with the Death in Custody Reporting Act of

2013 (“DCRA”), Pub. L. No. 113-242, 128 Stat. 2860 (codified as amended in scattered sections

of 34 U.S.C. and 14 U.S.C.).

After a search uncovered over 230,000 pages of documents potentially responsive to

plaintiff’s FOIA request, defendant invoked FOIA Exemption 3, 5 U.S.C. § 552(b)(3), to

withhold the release of all those materials under the confidentiality provision of the Omnibus

Crime Control and Safe Streets Act of 1968 (“Crime Control Act”), 34 U.S.C. § 10231. As a

result, the key question in this dispute, one of first impression in this Circuit, is whether the text

of the Crime Control Act’s confidentiality provision exempts disclosure of the requested 1 information under FOIA Exemption 3. In their cross-motions for summary judgment, the parties

offer divergent interpretations of the statute that favor their positions. For the reasons explained

below, plaintiff’s cross-motion for summary judgment, Pl.’s Cross-Mot. for Summ. J., ECF No.

13, is granted and defendant’s motion for summary judgment, Def.’s Mot. for Summ. J., ECF

No. 12, is denied.

I. BACKGROUND

The factual background and procedural history relevant to the pending motion are

described below.

A. Statutory Context

The DCRA was originally enacted in 2000 and, after expiration in 2006, reauthorized in

2014. See infra n.3. This law aims to “encourage States to report to the Attorney General

certain information regarding the deaths of individuals in the custody of law enforcement

agencies.” Pub. L. No. 113-242, 128 Stat. 2860 (2014). To fulfill that goal, the DCRA requires

certain states and federal law enforcement agencies to report to the Attorney General information

regarding the death of “any person who is detained, under arrest, or is in the process of being

arrested, is en route to be incarcerated, or is incarcerated” at a local or state jail, prison, boot

camp, contract facility, or other correctional facility, including juvenile facilities. See DCRA §

2(a), 128 Stat. at 2861 (outlining state reporting requirements); accord 34 U.S.C. 60105(a)

(codification of such state requirements); see also DCRA § 3(a), 128 Stat. at 2861 (outlining

federal law enforcement reporting requirements); 18 U.S.C. § 4001 note (codification of such

federal requirements). Both states and federal agencies must include “at a minimum” in their

disclosures “(1) the name, gender, race, ethnicity, and age of the deceased; (2) the date, time, and

location of death; (3) the law enforcement agency that detained, arrested, or was in the process of

arresting the deceased; and (4) a brief description of the circumstances surrounding the death.” 2 DCRA § 2(b) (listing information required of states); 34 U.S.C. § 60105(b) (codifying such);

accord DCRA § 3(b) (explaining that information required for federal agency reporting is the

same as that outlined in § 2(b) for states).

Compliance with the DCRA is required of those states that receive federal funds under

Title 1 of the Crime Control Act, see DCRA § 2(a), (c)(2); 34 U.S.C. § 60105(a), (c)(2), and

failure to comply when required with the DCRA’s reporting requirements makes a state, “at the

discretion of the Attorney General, [] subject to not more than a 10-percent reduction of the

funds” otherwise allocated to them under Title I of the Crime Control Act, “whether

characterized as the Edward Byrne Memorial State and Local Law Enforcement Assistance

Programs, the Local Government Law Enforcement Block Grants Program, the Edward Byrne

Memorial Justice Assistance Grant Program, or otherwise,” DCRA § 2(c)(2); 34 U.S.C. §

60105(c)(2). The Attorney General, through the Department of Justice and its Office of Justice

Programs (“OJP”), established the Mortality in Correctional Institutions (“MCI”) program to

collect the DCRA-mandated information. See Mortality in Correctional Institutions (MCI)

(Formerly Deaths in Custody Reporting Program (DCRP)), U.S. DEP’T OF JUSTICE OFFICE OF

JUSTICE PROGRAMS – BUREAU OF JUSTICE STATISTICS, https://bjs.ojp.gov/data-

collection/mortality-correctional-institutions-mci-formerly-deaths-custody-reporting-

program#methodology-0 (last visited Mar. 24, 2023).

The Crime Control Act, enacted in 1968 over thirty years earlier than the DCRA, sought

“[t]o assist State and local governments in reducing the incidence of crime, to increase the

effectiveness, fairness, and coordination of law enforcement and criminal justice systems at all

levels of government, and for other purposes.” Pub. L. No. 90-351, 82 Stat. 197 (1968) (codified

at 34 U.S.C. § 10151 et seq.). At issue in this dispute is Title I of the Act, named “Law

3 Enforcement Assistance,” intended “to assist State and local governments in strengthening and

improving law enforcement at every level by national assistance.” Crime Control Act, tit. I, 82

Stat. at 198. Congress provides such national assistance through federal grant programs

available to state law enforcement agencies. See id., tit. I, §§ 201–405, 82 Stat. at 198–204.

Title I also authorizes DOJ to “request any Federal department or agency to supply such

statistics, data, program reports, and other material as [DOJ] deems necessary to carry out its

functions under this title.” Id., tit. I, § 513, 82 Stat. at 207.

In 1979, Congress amended Title I by adding a confidentiality provision—the

interpretation of which is the central question in this case. The provision, as originally enacted,

states:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Fourco Glass Co. v. Transmirra Products Corp.
353 U.S. 222 (Supreme Court, 1957)
Environmental Protection Agency v. Mink
410 U.S. 73 (Supreme Court, 1973)
Department of the Air Force v. Rose
425 U.S. 352 (Supreme Court, 1976)
Federal Bureau of Investigation v. Abramson
456 U.S. 615 (Supreme Court, 1982)
Sedima, S. P. R. L. v. Imrex Co.
473 U.S. 479 (Supreme Court, 1985)
United States Department of Justice v. Julian
486 U.S. 1 (Supreme Court, 1988)
Davis v. Michigan Department of the Treasury
489 U.S. 803 (Supreme Court, 1989)
United States Department of Justice v. Tax Analysts
492 U.S. 136 (Supreme Court, 1989)
Ardestani v. Immigration & Naturalization Service
502 U.S. 129 (Supreme Court, 1991)
United States Department of Justice v. Landano
508 U.S. 165 (Supreme Court, 1993)
United States v. Braxtonbrown-Smith
278 F.3d 1348 (D.C. Circuit, 2002)
Morley v. Central Intelligence Agency
508 F.3d 1108 (D.C. Circuit, 2007)
Larson v. Department of State
565 F.3d 857 (D.C. Circuit, 2009)
United States v. Walter B. Spears
449 F.2d 946 (D.C. Circuit, 1971)

Cite This Page — Counsel Stack

Bluebook (online)
Gannett Satellite Information Network, LLC v. U.S. Department of Justice, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gannett-satellite-information-network-llc-v-us-department-of-justice-dcd-2023.