Mass Media Law 18th Edition Don Pember Clay Calvert Chapter 9 Gathering Information: Records and Meetings McGraw-Hill/Irwin © 2013 McGraw-Hill Companies. All Rights Reserved. News Gathering & the Law There are three primary sources of law to which journalists might look for a legal right to access information: – Common law – Constitutional law – Statutory law 9-2 News Gathering & the Law Common law – Only provides bare access to government documents and meetings of public agencies 9-3 News Gathering & the Law Constitutional law – Historically, the First Amendment was seen as a means by which the public could confront its government, not necessarily report on its activities. – The Supreme Court has found no unrestrained right of journalists to gather information beyond that of the average citizen. 9-4 News Gathering & the Law Constitutional law – In three cases involving prisons, the Supreme Court found the First Amendment does not guarantee a journalist the unobstructed right to gather news in such a setting. – The Court has ruled that there is a First Amendment right for all citizens to attend a criminal trial. 9-5 News Gathering & the Law Constitutional law: Access to Government Officials – Members of the press have no special right of access to government officials to conduct one-on-one private interviews. – Recent cases suggest that government officials cannot selectively deny access to specific reporters from public press conferences that are open to all members of the news media. 9-6 The First Amendment Protection of News Gathering Journalists today are being sued not just for how they report the news, but increasingly for how they gather the news: – Trespass – Harassment – Fraud – Failure to obey lawful orders – Taping and recording 9-7 The First Amendment Protection of News Gathering Trespass: Definition – Trespass is an intentional, unauthorized entry onto land that is occupied or possessed by another. – Reporters may face civil liability and criminal prosecution when they trespass. 9-8 The First Amendment Protection of News Gathering Trespass: Defenses – Consent may be a defense when journalists are invited or allowed onto private property. – When property is generally open to the public (businesses), and journalists do not otherwise interfere with the business use. 9-9 The First Amendment Protection of News Gathering Trespass: Ride Alongs – Government agents (police, firefighters) cannot give permission to reporters or photographers to enter private property. – Government agents and the journalists can be held accountable for trespass or violations of the Fourth Amendment – illegal search and seizure. 9-10 The First Amendment Protection of News Gathering Harassment – Journalists who hound, stalk, or undertake other unreasonable surveillance methods may be charged with harassment. 9-11 The First Amendment Protection of News Gathering Fraud – Fraud is a knowingly false statement of a material or significant fact that is communicated with the intent to induce the plaintiff to rely on that statement and that does, in fact, induce the plaintiff to reasonably rely upon it to the plaintiff’s harm or injury. – Journalists cannot lie to gain access to otherwise private property or information. 9-12 The First Amendment Protection of News Gathering Failure to obey lawful orders – Reporters must respect orders from police and fire officials at the scene of disasters, accidents and fires or face disorderly conduct or other criminal charges 9-13 The First Amendment Protection of News Gathering Taping and recording – In some states, the secret recording of conversations can lead to prosecution. – Nearly half of all states and the federal government have laws against eavesdropping. – One-party consent states allow secret recording of conversations. All-party consent states require reporters to obtain permission from all parties before recording. 9-14 The Freedom of Information Act FOIA: Overview – The Freedom of Information Act (FOIA) provides a statutory right of access to records possessed by federal government agencies. – This is a critical tool for journalists. 9-15 The Freedom of Information Act FOIA: Applying the Law – The federal government has often been hostile to FOIA requests made by reporters. – The Bush Administration, especially following 9-11, has been highly restrictive in its release of information to the public via FOIA requests. – After 9/11, the nation’s record-keepers have followed the “when in doubt, don’t let it out” approach. 9-16 The Freedom of Information Act FOIA: Electronic Communication – In 1996, Congress adopted an amendment to the FOIA, known as e-FOIA, that requires government agencies to apply the same standards of disclosure to electronic records that they have always applied to paper documents. – The law does not define “electronic information,” leaving this important question to federal agencies and the courts. 9-17 The Freedom of Information Act FOIA: Agency Records – An agency is defined as any executive department, military department, government corporation, government-controlled corporation or other establishment in the executive branch of government, or any independent regulatory agency 9-18 The Freedom of Information Act FOIA: Agency Records – Though physical characteristics were not specified in the Freedom of Information Act, records include: • • • • • • Paper documents E-mail Computer-generated materials Films Tapes Three-dimensional objects, such as evidence 9-19 The Freedom of Information Act FOIA: Agency Records – Courts define “agency record” as: 1. If record is created or obtained by an agency, and under agency control at the time of the FOIA request, it is very likely an agency-record. 2. If the agency has created the document but does not possess or control it, it is not an agency record. 3. If the agency merely possess the document, but has not created it, it might or might not be an agency record. 9-20 The Freedom of Information Act FOIA: Exemptions – The FOIA has nine specific statutory exemptions and is limited by recent laws, such as the Homeland Security of Act of 2002, that create specific exceptions from FOIA requirements. 9-21 The Freedom of Information Act FOIA: Nine Exemptions 1. National security matters 2. Housekeeping materials 3. Material exempted by statute 4. Trade secrets 5. Working papers and lawyer-client privileged documents 9-22 The Freedom of Information Act FOIA: Nine Exemptions 6. Personal privacy files 7. Law enforcement records 8. Financial institution materials 9. Geological data 9-23 The Freedom of Information Act National Security (Exemption 1) – Exemption 1 covers matters specifically authorized under criteria established by an executive order to be kept secret in the interest of national defense or foreign policy. 9-24 The Freedom of Information Act National Security (Exemption 1) • Courts rule in favor of the government on Exemption 1 if an agency’s affidavits: 1. Describe justifications for nondisclosure in reasonably specific detail, 2. Demonstrate the information withheld logically falls within the claimed exemption, and 3. Are not contradicted by evidence in the record or by evidence of agency bad faith. 9-25 The Freedom of Information Act Homeland Security Act Exemptions – Created in response to September 11, 2001. – “Critical infrastructure information” voluntarily submitted to the Homeland Security Department by private persons and business entities. – Grants companies immunity for civil and criminal liability relating to any information that they voluntarily submit. 9-26 The Freedom of Information Act Housekeeping Practices (Exemption 2) – Protects from disclosure material that is “related solely to the internal personnel rules and practices of an agency. 9-27 The Freedom of Information Act Statutory Exemption (Exemption 3) – Covers matters specifically exempted from disclosure by statute. Courts typically ask three questions when evaluating applicability of this exemption: 1. Is there a specific statute that authorizes or requires the withholding of information? 2. Does the statute outline specific criteria for information that may be withheld? 3. Does the record or information that is sought fall within the categories of information that may be withheld? 9-28 The Freedom of Information Act Statutory Exemption (Exemption 3) – The CIA has managed to use this exemption to almost completely shield its operations from public scrutiny. 9-29 The Freedom of Information Act Trade Secrets (Exemption 4) – This exemption covers trade secrets and financial or commercial information. – Only applies if a 3-part test is satisfied: 1. The information for which the exemption is sought must be a trade secret or commercial or financial in character 2. It must be obtained from a person 3. It must be privileged or confidential 9-30 The Freedom of Information Act Working Papers / Discovery (Exemption 5) – This exemption shields working papers such as studies, reports, and memoranda that are prepared to assist decision-makers in developing policy. – The exemption also protects communications between an agency and its attorney. – The documents typically must be pre-decisional and deliberative. 9-31 The Freedom of Information Act Personal Privacy (Exemption 6) – This exemption shields “personnel and medical files and similar files.” – “Similar files” are those that contain highly personal information of the same magnitude as that contained in personnel or medical records. 9-32 The Freedom of Information Act Law Enforcement (Exemption 7) – This exemption covers records compiled for law enforcement purposes, whose disclosure would: a. b. c. d. e. f. Interfere with enforcement proceedings, Deprive a person of a right to fair trial, Constitute an unwarranted invasion of personal privacy, Disclose the identity of confidential sources, Disclose law-enforcement techniques that might risk circumvention of the law, or Endanger the life or physical safety of any individual. 9-33 The Freedom of Information Act Financial and Geological Data (Exemptions 8 / 9) – Exemption 8 protects financial reports or audits whose public disclosure would undermine public confidence in financial institutions. – Exemption 9 prevents speculators and other drillers from gaining access to valuable information about oil wells. 9-34 The Freedom of Information Act Handling FOIA Requests – Government departments must answer requests for records and documents within 20 business days. – If an appeal is filed after a denial, the agency has only 20 days to rule on the appeal. 9-35 The Freedom of Information Act Handling FOIA Requests – Fees for FOIA requests are based on the kind of requester: 1. Commercial-use requesters must pay fees for document search, duplication and review. 2. Non-commercial requesters from educational or scientific institutions pay no search fees and receive one hundred pages of free duplication. 3. Representatives of the news media pay no search fees and receive copies of one hundred pages free. 4. All other requesters receive two hours of search time and one hundred pages at no charge. 9-36 The Freedom of Information Act FOIA Online Resources – Five excellent on-line resources to consult for further information: • • • • • • The FOIA Project National Security Archive (George Washington University) Freedom of Information Center (University of Missouri) Reporters Committee for Freedom of the Press FOIA Guide US Department of Justice, FOIA Information Center Federal Communications Commission (FCC) FOIA Center 9-37 The Freedom of Information Act Federal Open-Meetings Law – Government in Sunshine Act, 1976 • Applies to 50 federal bodies. • Courts have interpreted this law to apply only to those bodies appointed by the President. • There are 10 exemptions to the Act that allow for closed meetings; the 9 FOIA exemptions plus an arbitration exemption. 9-38 State Law on Meetings and Records State Open-Meetings Laws – All 50 states have specific statutes that mandate open meetings. Most open-meetings laws: • Provide for closed meetings, or executive sessions, in certain kinds of cases, and • Require advance public notice of regular and special meetings. 9-39 State Law on Meetings and Records State Open-Records Laws – Every state has some kind of open-records law. Most state laws permit inspection of records by any person; some allow inspection only by citizens of that state. 9-40 State Law on Meetings and Records State Open-Records Laws: Common Exemptions – Six common exemptions to state open-records laws are: 1. Information classified as confidential by state or federal law 2. Law enforcement and investigatory information 3. Trade secrets and commercial information 4. Preliminary departmental memorandums (working papers) 5. Personal privacy information 6. Information relating to litigation against a public body 9-41 State Law on Meetings and Records The Privatization of Public Government – For-profit and non-profit organizations are now operating state facilities such as schools, prisons and welfare agencies. These private organizations do not have the same legal obligations to provide access to meetings and records. 9-42 Laws that Restrict Access to Information School Records: The Buckley Amendment – The Family Educational Rights and Privacy Act (sometimes called the Buckley Amendment) permits parents to review their children’s educational records. – The act also prohibits the dissemination of personally identifiable information, excluding directory data, to unauthorized persons without the consent of parents 9-43 Laws that Restrict Access to Information Health and Medical Records: HIPAA • Limits the ability of journalists to obtain information about patients in hospitals and other healthcare settings. • Journalists can obtain information about crime victims from law enforcement sources without violating this law as HIPPA applies only to healthcare and health insurance providers. 9-44 Laws that Restrict Access to Information The Federal Privacy Law – The Privacy Act of 1974 attempts to check the misuse of personal data obtained by the federal government. It also provides access for individuals to records about themselves that are held by federal agencies. – Each federal agency must limit the collection of information to that which is relevant and necessary, comes directly from the subject concerned, and allows individuals to review and amend their personal records. 9-45 Laws that Restrict Access to Information Criminal History Privacy Laws – Press access to criminal history records kept by the police has been virtually eliminated unless: • Data sought are pertinent to an incident for which a person is currently being processed by the criminal justice system, • They are conviction records, or • They are accessible only on that basis. 9-46 Laws that Restrict Access to Information State Statutes that Limit Access to Information – All states have statutes that limit access to information that would otherwise be available under a freedom of information law. – All the states and the federal government have laws that specifically exclude certain kinds of information from public scrutiny 9-47