Sullivan v. Central Intelligence Agency’s Empirical Analysis
992 F.2d 1249 · 1993
Citation profile
19 federal appellate · 11 district ·
How this case has been cited
Cited by 44 later decisions — most recently April 2018 · most notably Morley v. Central Intelligence Agency (2007), Pritzker v. Yari (1994)
19 federal appellate · 11 district ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 5 U.S.C. § 552 (Freedom of Information Act) · 50 U.S.C. § 431 (§ 701 of the National Security Act of 1947)
Relies on Morales v. Trans World Airlines, Inc. · Fmc Corporation v. Holliday · Public Citizen v. United States Department of Justice · Central Intelligence Agency v. Sims · Griggs-Ryan v. Smith
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 44 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“As the statute’s language and legislative history make clear, a congressional investigation that touches on CIA conduct in a particular incident or region, standing alone, is not sufficient to warrant the release of all CIA documents anent that incident or region. Instead, the congressional investigation and the documents sought must specifically relate to CIA wrongdoing, that is, some “impropriety” or “violation of law” in the conduct of the designated intelligence activity. The primary mission of the Church Committee, as appellant admits, was to examine the relationship, if any, between the assassination of President Kennedy, on the one hand, and American-sponsored operations against Cuba, on the second hand. In the course of its work, the Committee considered American op erations against Castro and, inevitably, their legality. Seen from that perspective, the Committee’s mission does not fit within the contours of section 431(c)(3) for two reasons. First, the Committee’s inquiry was not a direct investigation into CIA wrongdoing. Second, appellant’s request for information about her father’s disappearance bears no claimed or readily discernible relationship to the investigation’s purposes.”
1 later decision quote this exact passage · from the majority“subject to search and review for information concerning ... any special activity the existence of which is not exempt from disclosure under the provisions of [FOIA.] ... or the specific subject matter of an investigation by the congressional intelligence committees, the Intelligence Oversight Board, the Department of Justice, the Office of General Counsel of the Central Intelligence Agency, the Office of Inspector General of the Central Intelligence Agency, or the Office of the Director of National Intelligence for any impropriety, or violation of law, Executive order, or Presidential directive, in the conduct of an intelligence activity. •”
1 later decision quote this exact passage · from the majority“[A] pivotal requirement of section 431(c)(3) is that, to be extractable, the information requested must concern the specific subject matter of the official investigation. Thus, although there were instances in which the Committee searched for agency misconduct, that happenstance does not allow appellant to catapult herself over the statutory parapet. It is simply not enough that information which bore in some remote way on the request surfaced in the course of an official investigation.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.