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FIA-14-0039 - In the Matter of Tim Hadley

On July 21, 2014, OHA issued a decision denying a FOIA Appeal filed by Tim Hadley (Appellant) of a determination issued by the Office of Information Resources (OIR).  OHA also dismissed two other Appeals filed by the Appellant of determinations issued by Office of the Inspector General (OIG) and Oak Ridge Office (Oak Ridge), respectively, on procedural grounds.  In his Appeal of the OIR determination, Mr. Hadley challenged OIR’s withholdings under Exemptions 5, 6, and 7(C).  However, OHA found that OIR properly applied the cited exemptions in withholding the information.  OHA determined that the information withheld under Exemption 5 was predecisional and reflected the give-and-take of the consultative process.  Further, release of the information would not be in the public interest because there was no public interest in the disclosure.  OHA further found that the information withheld under Exemptions 6 and 7(C) was information that applied to particular individuals, such as names, initials, and signatures; titles; and telephone numbers.  The information identifying the names and signatures of the current federal OIG employees whose information was withheld, would also compromise a significant privacy interest.  Federal employees involved in law enforcement possess protectable privacy interests in their identities.  OHA has consistently found that OIG is a law enforcement agency.  Release of any information could result in identifying those OIG employees.  In balancing the privacy interests found, OHA considered whether release would further the public interest by shedding light on the operations and activities of the government.  OHA found that the public interest in the withheld information is minimal at best.  Therefore, the privacy interest outweighed the public interest and, accordingly, OHA denied the Appeal.