Washington Law Review


This Comment analyzes the approaches of the courts of appeals to the confidential source exemption. First, the Comment presents a brief history of the Freedom of Information Act and the development of exemption 7(D) in Congress and the courts. The Comment explains and criticizes the conflicting judicial treatment of the agency's burden under the exemption. Finally, the Comment proposes a uniform approach to the agency burden that is consistent with the policies underlying both the Act and the exemption.

First Page