Judicial Watch, Inc. v. Social Security Administration

CourtDistrict Court, District of Columbia
DecidedAugust 1, 2011
DocketCivil Action No. 2006-2034
StatusPublished

This text of Judicial Watch, Inc. v. Social Security Administration (Judicial Watch, Inc. v. Social Security Administration) 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
Judicial Watch, Inc. v. Social Security Administration, (D.D.C. 2011).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ JUDICIAL WATCH, INC., ) ) Plaintiff, ) ) v. ) Civil Action No. 06-2034 (RCL) ) SOCIAL SECURITY ADMIN., ) ) Defendant. ) ____________________________________)

MEMORANDUM OPINION

I. INTRODUCTION

Is an employer a taxpayer? That deceptively simple question is the conundrum before the

Court today. Plaintiff Judicial Watch, Inc. (“JW”) is suing the Social Security Administration

(“SSA”), requesting a list of the names and addresses of employers who received the most “no-

match” letters during a five-year time period. A “no-match” letter occurs when the SSA detects

a mismatch between an employee’s name and social security number. The SSA refuses to

divulge this information, citing Freedom of Information Act (“FOIA”) Exemption 3 as the basis

for its refusal. The case is before the Court on the parties’ cross-motions for summary judgment.

Having reviewed the motions, the oppositions, the replies, the entire record in the case, and the

applicable law at length, the Court grants the SSA’s motion for summary judgment and denies

JW’s cross-motion for summary judgment for the reasons that follow.

II. BACKGROUND

A. Statutory Framework

FOIA allows the public to gain access to records from a federal administrative agency,

Valencia-Lucena v. U.S. Coast Guard, 180 F.3d 321, 325 (D.C. Cir. 1999), and represents a strong Congressional commitment to transparency in government through the disclosure of

government information. Dep’t of the Air Force v. Rose, 425 U.S. 352 (1976). FOIA strikes a

balance between “ensur[ing] an informed citizenry, vital to the functioning of a democratic

society,” and “legitimate governmental and private interests [that] could be harmed by [the]

release of certain types of information.” Critical Mass Energy Project v. Nuclear Regulatory

Comm’n, 975 F.2d 871, 872 (D.C. Cir. 1992).

Although FOIA embodies a policy of disclosure, full disclosure cannot always be

achieved. 5 U.S.C. § 552(b)(1)–(9) (2006). There are nine exemptions that allow an agency to

withhold all or parts of a document. Id. While these exemptions allow agencies to withhold

information, FOIA requires that “any reasonably segregable portion of a record shall be provided

to any person requesting such record after deletion of the portions which are exempt under this

subsection.” 5 U.S.C. § 552(b)(1). FOIA Exemption 3 is in play in this case—it allows an

agency to withhold documents that have been specifically exempted from disclosure by another

statute, “provided that such statute (A) requires that the matters be withheld from the public in

such a manner as to leave no discretion on the issue, or (B) establishes particular criteria for

withholding or refers to particular types of matters to be withheld.” 5 U.S.C. § 552(b)(3).

The relevant statute at issue here is 26 U.S.C. § 6103, which grants an agency the

authority to withhold a document in its entirety simply because it pertains to a confidential tax

return or “return information.” 26 U.S.C. § 6103(a). The Supreme Court and the District of

Columbia Circuit Court of Appeals have held that § 6103 qualifies as a FOIA Exemption 3

statute. See Church of Scientology of Cal. v. IRS, 484 U.S. 9, 11 (1987) (“If § 6103 forbids the

disclosure of material, it may not be produced in response to a request under FOIA”); see also

2 Tax Analysts v. IRS, 117 F.3d 607, 611 (D.C. Cir. 1997) (“That § 6103 is the sort of

nondisclosure statute contemplated by FOIA Exemption 3 is beyond dispute”).

Section 6103(b) excludes from the category of return information “data in a form which

cannot be associated with, or otherwise identify, directly or indirectly, a particular taxpayer.” 26

U.S.C. § 6103(b)(2). Known as the Haskell Amendment, this provision allows the IRS to

“release for research purposes statistical studies and compilations of data, such as the tax model,

which do not identify individual taxpayers.” Church of Scientology, 484 U.S. at 16. In Church

of Scientology, the Supreme Court clarified that the Haskell Amendment only applies to

information that has been “reformulated” into “a statistical study or some other composite

product.” Id. at 13–18. Thus, the Haskell Amendment does not apply to information that an

agency simply transfers from one document to another. Id. at 13.

B. Factual and Procedural History

On June 6, 2006, JW submitted a FOIA request to the SSA for a list of the top fifty or top

one hundred U.S. employers who received “the highest number of Social Security number

mismatches.” Def.’s Mot. Summ. J. 3, Apr. 18, 2007, ECF No. 9 (“Def.’s Mot.”). JW sought

these records for a five-year time period beginning on January 1, 2001 and extending to 2006.

Liptz Declaration 4, Ex. B to Def.’s Mot., Apr. 18, 2007, ECF No. 9-2 (“Liptz Decl.”). An

employer receives a “no-match” letter from the SSA when a mismatch occurs between an

employee’s name and the social security number on her filed W-2 form. Def.’s Mot. 3; Liptz

Decl. 2. The SSA determines which employers will receive “no-match” letters using the W-2

forms that employers file.1 Def.’s Mot. 4.

1 The SSA collects the following information from W-2 forms: the employer’s name and identification number; the employee’s name, address, and social security number; and the amount of wages paid. Liptz Decl. 2.

3 The SSA denied JW’s FOIA request by a letter dated June 29, 2006, explaining that “no-

match” letters are considered tax return information and are exempt from disclosure. Id. at 6.

Willie J. Polk, the SSA Freedom of Information Officer assigned to handle JW’s request,

determined that 26 U.S.C. § 6103 prohibited the disclosure of such a list because the SSA

generated this list from tax returns filed with the Internal Revenue Service (“IRS”).2 Id. Polk

included instructions detailing the procedure for an administrative appeal if JW did not agree

with the SSA’s assessment of its FOIA request. Letter from SSA to JW 13, Ex. A to Def.’s

Mot., Apr. 18, 2007, ECF No. 9-1 (incorporated as Exhibit 2 to Exhibit A) (“SSA Response 1”).

JW administratively appealed the SSA’s decision, by a letter dated August 2, 2006. Def.’s Mot.

4. The SSA again denied JW’s request on October 16, 2006, citing 26 U.S.C.

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