McAtee v. United States Department of Homeland Security, United States Secret Service
Filing
34
ORDER granting in part 19] Motion for Summary Judgment; denying in part 23 Motion for Summary Judgment. See Order for additional deadlines. Signed by Judge Donald W. Molloy on 5/31/2016. (DLE)
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MONTANA
MISSOULA DIVISION
DEANNA McATEE,
CV 15–84–M–DWM
Plaintiff,
vs.
ORDER
UNITED STATES DEPARTMENT
OF HOMELAND SECURITY,
UNITED STATES SECRET
SERVICE,
Defendant.
INTRODUCTION
Plaintiff Deanna McAtee brings this action against the United States Secret
Service, a component of the United States Department of Homeland Security,
alleging noncompliance with the Freedom of Information Act (“FOIA”), 5 U.S.C.
§ 552. McAtee seeks a declaration that the Secret Service violated FOIA by
failing to provide her with timely and full responses to her FOIA requests, an
order requiring the Secret Service to immediately and fully provide her with all
records relating to its investigation of her, and an award of costs and attorneys’
fees. Both parties seek summary judgment. (Docs. 19, 23.) For the reasons stated
-1-
below, the Secret Service’s motion is granted in part, McAtee’s motion is denied
in part, and the parties are ordered to make supplemental filings.
BACKGROUND
On May 2, 2012, the United States filed an indictment in this Court
charging McAtee with bank and wire fraud related to real estate transactions
involving Whitefish Credit Union and other individuals. (Def.’s Statement of
Disputed Facts, Doc. 28 at 3–4 (referencing CR 12–22–M–DLC, Doc. 1).) The
indictment was dismissed without prejudice on September 24, 2012. (Doc. 28 at 5
(referencing CR 12–22–M–DLC, Doc. 15).)
On August 8, 2013, the Secret Service received a FOIA request from
McAtee requesting her “complete criminal file in it’s [sic] entirety including all
investigative reports, wire taps, sworn statements, written statements, interviews
and field notes of investigating officers.” (Pl.’s Statement of Disputed Facts, Doc.
30 at 5; Doc. 16-1.) The Secret Service responded on September 7, 2013, and
informed McAtee that the request could not be completed as she had not provided
certification of her identity. (Docs. 30 at ¶ 2; 16-2.) The case was
administratively closed on November 2, 2013. (Doc. 30 at ¶ 2; Magaw Decl., Doc.
16 at ¶ 6.)
On April 7, 2014, the Secret Service received a letter from McAtee dated
-2-
February 25, 2014, resubmitting her FOIA request. (Docs. 30 at ¶ 3; 16-3.) The
Secret Service acknowledged the request on April 15, 2014, advising that there
may be a delay in processing the request “[d]ue to the increasing number of
FOIA/PA requests received by [the] office.” (Docs. 28 at ¶ 10; 16-4.) By letter
dated May 8, 2014, the Secret Service notified McAtee that it had located the
documents and that it was reviewing them for “releasability.” (Docs. 28 at ¶ 11;
16-5.) By letter dated September 17, 2014, the Secret Service notified McAtee
that it had erroneously mailed previous letters to her physical rather than mailing
address and enclosed earlier letters that had not reached her. (Docs. 28 at ¶ 12; 81 at 12.) On January 7, 2015, after an unsuccessful attempt to e-mail a request,
counsel representing McAtee successfully faxed an additional request for records
to the Secret Service on McAtee’s behalf. (Docs. 30 at ¶ 4; 8-1 at 13.)
On March 11 and April 13, 2015, the Secret Service sent McAtee responses
to her requests, which included a DVD interview of McAtee, documents released
in full, documents redacted per various exemptions, and a notification of
documents withheld in full per various exemptions. (Docs. 28 at ¶ 14; 30 at ¶¶
8–9; 16-7; 16-8.) McAtee appealed both releases. (Docs. 30 at ¶ 10; 16-9; 16-10.)
McAtee commenced this action on July 8, 2015. (Doc. 1.) On September 4, 2015,
the Secret Service responded to McAtee’s appeals, upholding its earlier response
-3-
and releasing additional documents responsive to her request. (Docs. 28 at ¶ 10;
16-11.)
Ultimately, the Secret Service released its investigative file on McAtee,
which included a video with redactions, 450 pages released in full, 41 pages
withheld in full, and 163 pages released with redactions.1 During its review, the
Secret Service also referred pages from the file to the Executive Office of the
United States Attorney’s Office because information on the pages originated
within a United States Attorney’s Office. (Docs. 30 at ¶ 13; 16-12; 16-13.) The
Executive Office completed its review on March 3, 2016, and its response
included 3 pages released in full and 29 pages withheld in full. (Docs. 32-1; 33;
33-1.)
McAtee claims the Secret Service conducted an unreasonable search and
that it improperly withheld, redacted, and referred documents. The Secret Service
claims it properly withheld, redacted, and referred the documents. To support its
response to McAtee’s request, the Secret Service has filed a Declaration of Craig
D. Magaw, FOIA appeals authority for the Secret Service (Doc. 16), a Vaughn
1
According to the Secret Service, it processed a total of 663 pages made up of 467 pages
released in full, 40 pages withheld in full, and 156 pages released with redactions. (Docs. 30 at
¶¶ 12, 15; 16 at ¶¶ 29–31.) However, that breakdown does not appear to correspond with the
Bates numbered documents filed by the Secret Service. (See generally Doc. 29-1.)
-4-
Index2 (Doc. 16-14), and 268 Bates Numbered Redacted Pages, (Doc. 29-1).
STANDARD
Summary judgment is proper where “the movant shows that there is no
genuine issue as to any material fact and the movant is entitled to judgment as a
matter of law.” Fed. R. Civ. P. 56(a). The parties agree this case is properly
decided on summary judgment, as is often appropriate in FOIA actions where facts
are rarely in dispute. Minier v. CIA, 88 F.3d 796, 800 (9th Cir. 1996).
DISCUSSION
To determine which party is entitled to summary judgment, courts employ a
three-step inquiry. Am. Civil Liberties Union of N. Cal. v. FBI, __ F. Supp. 3d __,
2015 WL 7251928, at *2 (N.D. Cal. Nov. 17, 2015). The first step is to determine
whether the agency met its burden of showing that it fully discharged its FOIA
obligations. Id. The second step is to determine whether the agency met its
burden of demonstrating that the undisclosed information falls within one of the
nine FOIA exemptions. Id. The final step is to determine whether the agency met
its burden of establishing that “all reasonably segregable portions of a document
have been segregated and disclosed.” Id. (quoting Pac. Fisheries, Inc. v. United
States, 539 F.3d 1143, 1148 (9th Cir. 2008)). These steps are addressed in turn
2
See Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973).
-5-
below.
I.
FOIA Obligations
To meet its burden, the agency must “demonstrate that it has conducted a
‘search reasonably calculated to uncover all relevant documents.’” Zemansky v.
U.S. Envtl. Prot. Agency, 767 F.2d 569, 571 (9th Cir. 1985) (quoting Weisberg v.
U.S. Dep’t of Justice, 745 F.2d 1476, 1485 (D.C. Cir. 1984)). The issue is whether
the search procedures and the agency’s response were adequate, which “is judged
by a standard of reasonableness and depends, not surprisingly, upon the facts of
each case.” Id. “In demonstrating the adequacy of the search, the agency may rely
upon reasonably detailed, nonconclusory affidavits submitted in good faith.” Id.
A.
Search Conducted
McAtee claims the Secret Service did not perform a reasonable search
because the search and processing it performed was dilatory and in violation of the
20-day deadline prescribed in 5 U.S.C. § 552(a)(6)(A)(i). The Secret Service
concedes that it “was not able to complete its review and analyze the results for
proper exemptions within the statutory time period,” (Doc. 31 at 2), but insists that
the delay does not entitle McAtee to judgment in her favor. The Secret Service is
correct. An untimely response is actionable in court but only in so far as the
requester seeks the court’s assistance in ordering the agency to complete its
-6-
response or the requester claims that the agency has a pattern and practice of
unreasonable delay in responding to FOIA requests. See 5 U.S.C. § 552(a)(4)(B)
(“On complaint, the district court . . . has jurisdiction to enjoin the agency from
withholding agency records and to order the production of any agency records
improperly withheld from the complainant.”); Gilmore v. U.S. Dep’t of Energy, 33
F. Supp. 2d 1184, 1188 (N.D. Cal. 1998) (“[T]his Court has jurisdiction over
Gilmore’s claim that the [agency] has a pattern or practice of untimely responses
to FOIA requests.”). If the agency has completed its review and responded, “the
only issue for the Court to consider . . . is whether the [agency’s] response
complies with its obligations under FOIA.” Hainey v. U.S. Dep’t of the Interior,
925 F. Supp. 2d 34, 42 (D.C. Cir. 2013) (citing Perry v. Block, 684 F.2d 121, 125
(D.C. Cir. 1982) (“We are not authorized to make advisory findings of legal
significance on the character of the agency conduct . . . . [I]if we are convinced
that [the agencies] have, however belatedly, released all nonexempt material, we
have no further judicial function to perform under the FOIA.”)). Because McAtee
does not dispute that she has received a final response to her request and she does
not allege a pattern or practice of untimely responses, her timeliness claim is moot.
See Carter v. Veterans Admin., 780 F.2d 1479, 1481 (9th Cir. 1986) (“[S]ince
Carter’s complaint sought injunctive relief directing the [agency] to provide the
-7-
documents he requested, it was mooted when the [agency] voluntarily mailed
copies of the regulations to Carter.”). Because McAtee raises no other challenges
to the search and there are no indications in the record of agency bad faith, the
search conducted by the Secret Service was reasonable.
B.
Pages Referred to Other Agency
McAtee claims the Secret Service’s referral of 31 pages to the Executive
Office of the United States Attorney’s Office constitutes an improper withholding
of documents. FOIA contemplates an agency’s consultation “with another agency
having a substantial interest in the determination of the request.” 5 U.S.C. §
552(a)(6)(B)(iii)(III). In line with that provision, an agency may refer documents
to an originating agency, but if the “net effect [of the referral] is significantly to
impair the requester’s ability to obtain the records or significantly to increase the
amount of time he must wait to obtain them,” the referral is deemed improper
withholding, unless the agency has a reasonable explanation for its procedure.
McGehee v. CIA, 697 F.2d 1095, 1110 (D.C. Cir. 1983), vacated in part on other
grounds, 711 F.2d 1076 (1983).
The referrals to the Executive Office do not constitute improper
withholding. According to the MaGaw Declaration, the Secret Service made an
initial referral of six pages one year after McAtee’s request and a second referral
-8-
of 25 pages 17 months after her request because the documents contained
information originating within a United States Attorney’s Office, specifically
communications of the prosecutor. (Doc. 16 at ¶¶ 34–36.) A review of the pages
referred shows that they are emails to or from the United States Attorney’s Office
as well as Secret Service Investigative Reports that contain details of the
investigation and judicial actions taken in the case against McAtee. (Doc. 29-1 at
13, 16, 18–33, 44, 46–48, 50, 53, 55–56, 65, 71, 73, 76, 78, 83.) The Secret
Service informed McAtee of both referrals, notified the Executive Office and
forwarded the documents to that agency, and continued to inquire into the progress
made on the referrals. (Doc. 16 at ¶¶ 34–36.) This procedure did not require
McAtee to submit a separate request to the Executive Office, and the Executive
Office was in the best position to determine whether the documents should be
withheld under Exemption 5 (which covers deliberative process, attorney-client
privilege, and attorney work-product privilege) or any other exemption. McAtee
has now received a complete, albeit belated, response from the Executive Office.
(Docs. 32-1; 33-1.) Aside from the delay that the referral caused—now a moot
issue—the Secret Service’s referral procedure is in line with the recommended
procedure for processing documents originating with other agencies. McGehee,
697 F.2d at 1111–12.
-9-
Nevertheless, McAtee is now faced with a response from the Executive
Office in which that agency is withholding 29 pages in full under numerous
exemptions. (Docs. 32-1; 33-1.) In its Status Report on the referrals, the Secret
Service did not attach the documents or the explanations of the Executive Office
because “it is unknown if [McAtee] will file an administrative review of the . . .
response.” (Doc. 33 at 2.) At this time, the Court is without sufficient information
to analyze the applicability of the claimed exemptions and make a segragability
determination as to the 29 pages.3 Additionally, the Court cannot review the
response until after McAtee has exhausted the appeals process as to the Executive
Office’s response. 5 U.S.C. § 552(a)(6)(A); Oglesby v. U.S. Dep’t of Army, 920
F.2d 57, 64 (D.C. Cir. 1990). Because the propriety of the 29 withheld pages is
not properly before the Court on the current motions, the parties shall file a joint
stipulation addressing the status of and proposed resolution for those pages.
II.
FOIA Exemptions
Agencies must make information available to the public unless the
information falls within one of the nine enumerated exemptions set forth in the
statute. 5 U.S.C. § 552(b). Exemptions must be narrowly construed. Shannahan
3
For this reason, the Court is also not in a position to address McAtee’s argument that
Exemption 5 does not apply to the pages referred to the Executive Office.
-10-
v. IRS, 672 F.3d 1142, 1148 (9th Cir. 2012). “FOIA’s strong presumption in favor
of disclosure places the burden on the government to show that an exemption
properly applies to the records it seeks to withhold.” Hamdan v. U.S. Dep’t of
Justice, 797 F.3d 759, 772 (9th Cir. 2015). The agency may carry that burden by
submitting affidavits and Vaughn indices, which are accorded substantial weight if
they “describe the justifications for nondisclosure with reasonably specific detail,
demonstrate that the information withheld logically falls within the claimed
exemptions, and show that the justifications are not controverted by contrary
evidence in the record or by evidence of [agency] bad faith.” Id. at 769 (quoting
Hunt v. CIA, 981 F.2d 1116, 1119 (9th Cir. 1992)). “[T]he government must
provide tailored reasons in response to a FOIA request. It may not respond with
boilerplate or conclusory statements.” Shannahan, 672 F.3d at 1148.
A.
Exemption under 5 U.S.C. § 552(b)(3)
Exemption 3 allows for withholding documents “specifically exempted from
disclosure by statute . . ., if that statute . . . (i) requires that the matters be withheld
from the public in such a manner as to leave no discretion on the issue.” 5 U.S.C.
§ 552(b)(3). The Federal Rules of Criminal Procedure, in turn, prohibit disclosure
of “a matter occurring before the grand jury.” Fed. R. Crim. P. 6(e)(2). “Rule 6(e)
applies if the disclosed material would tend to reveal some secret aspect of the
-11-
grand jury’s investigation including the identities of witnesses or jurors, the
substance of testimony, the strategy or direction of the investigation, or the
deliberations or questions of jurors.” Citizens for Responsibility & Ethics in
Wash. v. U.S. Dep’t of Justice, 746 F.3d 1082, 1100 (D.C. Cir. 2014) (quoting
Hodge v. FBI, 703 F.3d 575, 580 (D.C. Cir. 2013) (internal quotation marks
omitted)). “The [agency] bears the burden of demonstrating some nexus between
disclosure and revelation of a protected aspect of the grand jury’s investigation.”
Id. (internal quotation marks omitted). “There is no per se rule against disclosure
of any and all information which has reached the grand jury chambers.” Id.
(internal quotation marks and alteration omitted).
According to the Magaw Declaration, the Secret Service withheld and
redacted pages under Exemption 3 “as information that was obtained pursuant to a
Grand Jury investigation into plaintiff, or information pertaining to how that
Grand Jury investigation proceeded. This information includes Grand Jury
subpoenas, and the documents obtained via those subpoenas; names of individuals
subpoenaed in the Grand Jury investigation; and notes of the proceedings of the
Grand Jury investigation.” (Doc. 16 at ¶ 42.) Yet, the Vaughn Index does not
provide any detailed information as to each withheld or redacted page. Instead,
the Index repeats for every page the same statements that the page contains
-12-
“[i]nformation regarding proceeding and investigation of grand jury,” (Doc. 16-14
at 16, 18, 20–22, 38–49), or is a “[d]ocument obtained from the grand jury
proceeding and investigation,” (Doc. 16-14 at 27, 34). These conclusory and
boilerplate explanations are insufficient. Citizens for Responsibility & Ethics in
Wash., 746 F.3d at 1101. Although some of the requested records may fall under
Exemption 3, the Secret Service has not yet supplied sufficient information for the
Court to make that determination. Thus, the Secret Service shall submit a
supplemental Vaughn index with sufficient detail as to the pages withheld or
redacted under Exemption 3.
B.
Exemptions under 5 U.S.C. § 552(b)(6) and (b)(7)(C)
Exemption 6, the personal privacy exemption, allows for withholding
“personnel and medical files and similar files the disclosure of which would
constitute a clearly unwarranted invasion of personal privacy.” 5 U.S.C. §
552(b)(6). Exemption 7(C), the law enforcement personal privacy exemption,
allows for withholding “records or information compiled for law enforcement
purposes, but only to the extent that the production of such law enforcement
records or information . . . could reasonably be expected to constitute an
unwarranted invasion of personal privacy.” 5 U.S.C. § 552(b)(7)(C). Both
exemptions protect the names and identifying information of government
-13-
employees as well as private third parties whose identities are revealed in
government and law enforcement records. Bangoura v. U.S. Dep’t of Army, 607
F. Supp. 2d 134, 147 (D.D.C. 2009). Both exemptions balance individuals’
privacy interests in protecting information from disclosure against the public
interest in disclosure. Forest Serv. Emps. for Envtl. Ethics v. U.S. Forest Serv.,
524 F.3d 1021, 1024 n.2 (9th Cir. 2008). Exemption 7(C) is “more protective of
privacy” than Exemption 6 when it comes to balancing the “magnitude of the
public interest” required to override the respective privacy interests. Id. (quoting
U.S. Dep’t of Def. v. Fed. Labor Relations Auth., 510 U.S. 487, 497 n.6 (1994)).
McAtee specifically seeks the names of employees of Whitefish Credit
Union and its counsel, Morrison & Frampton, PLLP, documents provided to the
Secret Service by those entities, and correspondence and communications between
the Secret Service and those entities.4 (Doc. 24 at 5.) According to the Magaw
Declaration, the Secret Service redacted the names and personal identifying
information of third parties and justified its redactions as follows:
[T]he Secret Service balanced the public’s interest in disclosure against
the rights of these third parties to personal privacy, and determined that
4
Although the Secret Service also redacted the names and personal identifying
information of its agents, the names and personal identifying information of private citizens
appearing in mortgage-related documents, and account information for a criminal record
database, McAtee does not contest the propriety of those redactions. (See Doc. 24 at 3–7; 26 at
9–12; 32 at 8–12.)
-14-
the privacy rights of third parties outweighed any public interest in
disclosure. The Secret Service determined that there is no public
interest in the disclosure of third party names and identifying
information, because such information reveals nothing about the manner
in which the agency conducts its activities and does not disclose any
illegal activity on the part of the agency. The Secret Service considered
the potentially stigmatizing effect resulting from the appearance of third
party names in law enforcement files. The Secret Service also
recognized that disclosure of third party information might have the
effect of chilling future cooperation by third parties with law
enforcement agencies. The Secret Service is also particularly concerned
with the protection of personal information of third parties because the
agency’s investigative mission includes jurisdiction over identity crimes
and fraud.
(Doc. 16 at ¶ 50.) The Secret Service did not withhold any pages in full under
Exemptions 6 and 7(C), and it redacted the names and identifying information of
third parties without redacting the substance of the documents, including any
correspondence or communications. (See generally Doc. 29-1.) McAtee does not
allege that the Secret Service’s search was incomplete, and she does not cite any
particular pages where the redactions withhold the substantive information she
seeks. The only issue therefore is whether the Secret Service properly redacted
employee names under Exemptions 6 and 7(C). The Court concludes it did.
First, McAtee argues the redactions are improper because the individual
employees do not have privacy interests as they were working in the course and
scope of employment for private entities that cannot enjoy “personal privacy” as
-15-
protected under the exemptions. McAtee relies on Federal Communications
Commission v. AT&T, Inc., 562 U.S. 397 (2011), but in that case the Supreme
Court addressed whether corporations have “personal privacy” for the purposes of
Exemption 7(C) without addressing the privacy interests of employees. Id. at 400.
McAtee provides no other authority establishing that employees of corporations
do not have “personal privacy” themselves, and there is no legal reason to adopt
her theory.
Next, McAtee argues the Secret Service failed to identify the specific
personal privacy interests of these individuals. Yet, the Magaw Declaration
plainly identifies the stigma of being associated with an investigation and reasons
that the public interest is diminished because names and identifying information
reveal nothing about the conduct of the agency. (Doc. 16 at ¶ 50.) Courts have
repeatedly found that these considerations weigh in favor of nondisclosure
because the privacy interest of individuals mentioned in law enforcement records
is accorded great weight while the public interest in the disclosure of third-party
identifying information is minimal as disclosure does not inform citizens about
“what their government is up to.” Davis v. U.S. Dep’t of Justice, 968 F.2d 1276,
1282 (D.C. Cir. 1992) (quoting U.S. Dep’t of Justice v. Reporters Comm. for
Freedom of Press, 489 U.S. 749, 772 (1989)); accord Forest Serv. Emps. for
-16-
Envtl. Ethics, 524 F.3d at 1025 (“information about private citizens that is
accumulated in various governmental files but that reveals little or nothing about
an agency’s own conduct is not the type of information to which FOIA permits
access” (internal quotation marks omitted)).
Finally, McAtee does not allege misconduct on the part of the Secret
Service. Rather she seeks the contents of the investigative file because she
“believes [Whitefish Credit Union] and [Morrison & Frampton] made knowingly
false accusations in its civil complaint [against her], and fed these false
accusations to the Secret Service and the U.S. Attorney’s office to prompt criminal
charges against her.” (Doc. 24 at 4.) McAtee has filed civil complaints against
both entities, and it appears she seeks the requested information to aid in that
litigation. (Id.) She argues that the Court “should refuse to protect entities who
misuse the criminal justice system for monetary gain.” (Id. at 7.) The requester’s
reason for seeking the information, however, is irrelevant to the Court’s analysis.
Forest Serv. Emps. for Envtl. Ethics, 524 F.3d at 1025. In any event, “the public
interest sought to be advanced [must be] a significant one,” Nat’l Archives &
Records Admin. v. Favish, 541 U.S. 157, 172 (2004), and private litigation is not a
significant public interest warranting disclosure of private information, Brown v.
FBI, 658 F.2d 71, 75 (2d Cir. 1981). “FOIA was not intended to function as a
-17-
private discovery tool.” Nat’l Labor Relations Bd. v. Robbins Tire & Rubber Co.,
437 U.S. 214, 242 (1978).
III.
Segregation
The Secret Service must establish that all reasonably segregable portions of
withheld documents have been segregated and disclosed. Hamdan, 797 F.3d at
779. The Court is not yet in a position to make a segregability determination as to
both the documents withheld by the Executive Office and the documents withheld
and redacted under Exemption 3. As to the documents redacted under Exemptions
6 and 7(C), a review of the pages shows that all reasonably segregable portions
were disclosed, and only those portions that are exempt—identifying information
and not substantive information—was redacted. (See generally Doc. 29-1; Doc.
16 at ¶¶ 56–57.)
Accordingly, IT IS ORDERED that the Secret Service’s motion (Doc. 19) is
GRANTED IN PART. It is granted to the extent that the Secret Service conducted
a reasonable search and properly redacted information under Exemptions 6 and
7(C). The Court RESERVES ruling on the motion as to Exemption 3.
IT IS FURTHER ORDERED that McAtee’s motion (Doc. 23) is DENIED
IN PART. It is denied to the extent that the referral of pages to the Executive
Office does not constitute improper withholding and the Secret Service properly
-18-
redacted information under Exemptions 6 and 7(C). The Court RESERVES ruling
on the motion as to Exemption 3.
IT IS FURTHER ORDERED that the Secret Service shall file a
supplemental Vaughn index as to the pages redacted and withheld under
Exemption 3 within thirty (30) days of this Order.
IT IS FURTHER ORDERED that within thirty (30) days of this Order, the
parties shall file a joint stipulation as to the 29 pages withheld by the Executive
Office that informs the Court of the status of McAtee’s appeal, if any, and
proposes a supplemental briefing schedule or other resolution as to the pages. If
appropriate, the Secret Service should consider whether it should submit affidavits
from the Executive Office explaining the cited exemptions or whether the
Executive Office should appear as a party to this suit pursuant to Federal Rule of
Civil Procedure 19(a). See McGehee, 697 F.2d at 1112.
DATED this 31st day of May, 2016.
-19-
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?