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Administrative Law Keyed to Asimow
Chrysler Corporation v. Brown
Citation:
441 U.S. 281 (1979)Facts
Chrysler Corporation, as a party to numerous government contracts, was required to comply with Executive Orders 11246 and 11375, which mandate equal employment opportunity. The Office of Federal Contract Compliance Programs (OFCCP) regulations required Chrysler to submit affirmative action programs (AAPs) and Employer Information Reports (EEO-1) to the Defense Logistics Agency (DLA). In 1975, third parties made FOIA requests for Chrysler’s 1974 AAP for its Newark plant and a Compliance Review Report (CRR). DLA determined the materials were subject to disclosure under FOIA and OFCCP regulations. Chrysler filed suit in the District Court of Delaware seeking to enjoin the release, arguing that disclosure was barred by FOIA, inconsistent with the Trade Secrets Act, and an abuse of agency discretion. The District Court held that certain information fell within FOIA Exemption 4, but the Court of Appeals vacated, holding that OFCCP disclosure regulations provided the “authorization by law” required by the Trade Secrets Act.
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