Question: Scott Armstrong submitted a Freedom of Information Act FOIA request
Scott Armstrong submitted a Freedom of Information Act (FOIA) request that, among other things, called for the federal government to reveal a list of names of lower-level FBI agents who attended certain meetings at the White House during the mid 1980s. When the government refused to reveal the agents' names, Armstrong filed suit under the FOIA. Upholding this refusal, the district court agreed with the government's contention that the names of FBI agents should always be exempt from disclosure under the FOIA exemption for "personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy." On appeal, Armstrong argued that the district court erred in concluding that the FOIA's privacy exemption justifies a categorical rule that FBI agents' names are exempt from disclosure. Was Armstrong correct?
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