Holy Spirit Association for the Unification of World Christianity v. Central Intelligence Agency and Stansfield Turner

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• emphasizing that “we do not adopt appellant’s position—that Congress must give 19 contemporaneous instructions when forwarding congressional records to an agency. Nor do we direct Congress to act in a particular way in order to preserve its FOIA exemption for transferred documents”
• refusing to consider as evidence of congressional intent a letter “written as a result of [appellant’s] FOIA request and this litigation—long after the actual transfer [of the documents] to the CIA”
• comparing records at issue, the contents of which the agency appeared to be aware, with other records transferred to the agency in sealed cartons with instructions not to open with which the agency complied
• letter from Clerk of House of Representatives written after transfer of records does not establish congressional control
• in camera review needed when descriptions of the documents were primarily conclusory and often repeat the terms of the FOIA
• \[T]here is no evidence surrounding the generation of these CIA-created records indicating that Congress intended that they remain secret.\ (emphasis added)

Source: CourtListener parenthetical corpus (CC0).