Nixon v. Sampson

580 F.2d 514, 188 U.S. App. D.C. 251, 3 Media L. Rep. (BNA) 2006, 1978 U.S. App. LEXIS 12064
CourtCourt of Appeals for the D.C. Circuit
DecidedMarch 22, 1978
DocketNos. 75-2194—75-2196
StatusPublished
Cited by4 cases

This text of 580 F.2d 514 (Nixon v. Sampson) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nixon v. Sampson, 580 F.2d 514, 188 U.S. App. D.C. 251, 3 Media L. Rep. (BNA) 2006, 1978 U.S. App. LEXIS 12064 (D.C. Cir. 1978).

Opinion

Opinion for the Court filed by BAZELON, Chief Judge.

BAZELON, Chief Judge:

Section 101(b)(1) of the Presidential Recordings and Materials Preservation Act (the Act), Pub.L. 93-526 (1974), 88 Stat. 1695, 44 U.S.C. § 2107 (Supp. V 1975), directs the Administrator of General Services (the Administrator) to take custody of all “papers, documents, memorandums, transcripts, and other objects and materials which constitute the Presidential historical materials of Richard M. Nixon.” Appellee, Rose Mary Woods, sought to remove from the Administrator’s custody approximately fifty cartons of material that she claimed was her personal property. Appellants, Reporters Committee for Freedom of the Press, et al., (Reporters Committee), sought to prevent the removal of this material until regulations implementing the Act had been promulgated by the Administrator and accepted by Congress.1 On December 16, 1977, while this case was under consideration, these regulations became effective. 42 Fed.Reg. 63626 (1977).2

I

The background of this litigation is extraordinarily complex. Soon after leaving office Mr. Nixon entered into an agreement with the Administrator of General Services, Arthur F. Sampson, concerning the disposition of the former’s “Presidential historical materials.”3 Mr. Nixon later brought suit in district court to enforce the implementation of this agreement. Mr. Sampson was a named defendant. Shortly thereafter two [253]*253groups of plaintiffs, of which Reporters Committee was one, brought suit seeking to have these materials declared the property of the United States government, to enjoin their transfer to Mr. Nixon, and to gain access to them under the Freedom of Information Act. In one action Mr. Nixon was a named defendant, in another he was permitted to intervene. These two actions were ultimately consolidated with the suit brought by Mr. Nixon; the Watergate Special Prosecutor and Jack Anderson, a newspaper columnist, were both permitted to intervene in Mr. Nixon's suit, the former as a defendant and the latter as a plaintiff. See Nixon v. Administrator of General Services, 408 F.Supp. 321, 331-32 (D.D.C.1976); Nixon v. Sampson, 389 F.Supp. 107 (D.D.C.1975). These actions came collectively to be known as the “consolidated cases.”

On December 20, 1974, the day after the Act was signed into law, Mr. Nixon brought suit challenging its constitutionality. We stayed all action in the consolidated cases until the Act’s constitutionality could be determined. Nixon v. Richey, 168 U.S.App.D.C. 172, 513 F.2d 430 (1975). However, on August 7, 1975, appellee Rose Mary Woods sought leave to intervene in the consolidated cases in order to recover what she claimed were her personal papers. On September 2, we granted leave to intervene and modified our stay “to enable the District Court, in its discretion, to enter an order ... to authorize the return of the materials sought, nothing herein contained being intended to intimate any view as to the disposition by the District Court of any applications which may be made to it.” Joint Appendix (J.A.) at 35.

Ms. Woods subsequently intervened in the consolidated eases. She claimed that Ms. Mary M. Filippini, Administrative Assistant for the Office of Presidential Materials at the General Services Administration and prior to that a staff member of the Office of Presidential Libraries at the National Archives and Records Service, had examined certain materials and prepared a “List F” containing items that were “solely the personal materials and papers” of Ms. Woods.4 Ms. Woods sought to recover the approximately fifty cartons of material enumerated in List F. She appended an affidavit of Ms. Filippini in which the archivist stated that she had personally inspected and compiled List F, and that:

Basing my judgment on the same criteria used in collecting Nixon Presidential Materials from other White House staff members and staff offices prior to and since August 9, 1974, I find none of the items described on “List F” . . . to be “Presidential historical materials of Richard M. Nixon.”

J.A. at 89. Ms. Filippini appended to her affidavit an “Exhibit I” containing the “criteria” she had used in compiling List F. This Exhibit I was a White House memorandum of August 9, 1974, stating that:

Personal files include correspondence unrelated to any official duties performed by the staff member; personal books, pamphlets and periodicals; daily appointment books or log books; folders of newspapers or magazine clippings; and copies of records of a personnel nature relating to a person’s employment or service.

J.A. at 91. “Personal files” were those not considered to be historical materials.

Defendant Sampson answered Woods’ complaint and stated that he did not oppose her requested relief. No opposition was voiced by the Special Prosecutor or by any other defendant. Reporters Committee, however, a plaintiff in the case below, filed a “Protective Answer” opposing Woods’ complaint and denying that the materials sought were her personal property. J.A. at 116-18.

On November 19, Ms. Woods filed a motion for judgment on the pleadings stating that the contents of the Filippini affidavit were admitted by defendant Sampson “and remain uncontroverted.” J.A. at 125-26. Despite the opposition of Reporters Committee, the district court granted Ms. Woods’ motion on December 2, 1975. It [254]*254noted specifically that “Defendants do not oppose the relief sought by Plaintiff-Intervenor.” J.A. at 149.

Reporters Committee appealed. Defendant Sampson has filed a brief in this court arguing that the district court’s decision should be upheld.5

On March 25, 1976, before oral argument was held on appeal, this court ordered the parties to begin negotiations so as “to stipulate those materials as to which no controversy exists.” We took this step because it appeared “that at least a substantial number of the materials enumerated in List F are so plainly the personal and private property of appellee Woods and so lacking in historical or commemorative value or significance as to preclude any colorable claim that they fall within the reach of Section 101 of the Presidential Recordings and Materials Preservation Act. . . . ”

By the time of oral argument well over half of the materials on List F had been released to Ms. Woods because the parties had stipulated that they were so plainly lacking in historical significance as to preclude any colorable claim that they fell within the reach of Section 101 of the Act.6

II

Section 104(a) of the Materials Preservation Act, supra note 1, directs the Administrator to “submit to each House of the Congress a report proposing and explaining regulations that would provide public access” to the Presidential historical materials controlled by the Act. ' These regulations, however, were not in effect when Rose Mary Woods intervened in the consolidated cases to obtain the return of what she claimed were her personal papers. The ruling of the district court was thus that the affidavit of Ms.

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580 F.2d 514, 188 U.S. App. D.C. 251, 3 Media L. Rep. (BNA) 2006, 1978 U.S. App. LEXIS 12064, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nixon-v-sampson-cadc-1978.