Construe FOIA exemptions narrowly, in favor of disclosure
In two cases involving requests under the Freedom of Information Act (FOIA), Sotomayor wrote an opinion that declined to order the release of the requested information, explaining that she did not want to "unreasonably hamper agencies in their
decision-making." Thus, in Tigue v. DOJ, 2002, the panel denied a tax attorney's request for a memorandum written by a Deputy U.S. Attorney outlining the office's opinions and policies regarding tax investigations, notwithstanding that the memorandum had
been cited in a publicly released report. And in Wood v. FBI, 2005, while acknowledging that FOIA exemptions should be construed "narrowly, resolving all doubts in favor of disclosure," her opinion denied a reporter's request for an
FBI memorandum regarding local FBI agents accused of lying. She reasoned that the "unwarranted invasion of privacy" for the individuals whose names would be released outweighed the public interest in disclosing a government employee's identity.
