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Administrative Law—Freedom Of Information Act—Agency Secrecy Continues—Nlrb V. Sears, Roebuck & Co., 421 U.S. 132 (1975); Renegotiation Board V. Grunman Aircraft Engineering Corp., 421 U.S. 168 (1975), Greg Adams

Washington Law Review

Sears, Roebuck and Company brought an action under the Freedom of Information Act (FOIA) to compel disclosure of Advice and Appeals Memoranda issued by the General Counsel of the National Labor Relations Board. In ordering disclosure of both sets of documents, the district court held that Advice Memoranda qualified under the Act as "'instructions' [to staff] which affect a member of the public," but that Appeals Memoranda were "final opinions" which did not fall within the Act's exemption for "intra-agency memoranda." The Court of Appeals for the District of Columbia affirmed without opinion. In another case requiring interpretation of the …