Case Citator › Arthur M. Schiller v. National Labor Relations Board

Arthur M. Schiller v. National Labor Relations Board

Is it still good law? What later courts have actually done to this case.

Abrogated
Court
D.C. Circuit
Citation
964 F.2d 1205
Decided
Confirmed treatments
1
Flagged citations read
33 of 33
Citing cases (total)
33
Treatment dates
2011
Abrogated
A reviewed court treats this case as abrogated by later authority. Schiller v. National Labor Relations Board was abrogated on its broad reading of FOIA Exemption 2. In Schoenman v. Federal Bureau of Investigation and other later cases, courts identified the Supreme Court's Milner v. Department of the Navy decision as the change.
More on how this was screened

Schiller's separate rulings on Exemption 5 work product, segregability, and accurate Vaughn indexes remain in use. All 33 flagged citations have been read. The confirmed adverse treatment is listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

33 later cases cite Arthur M. Schiller v. National Labor Relations Board; 33 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Arthur M. Schiller v. National Labor Relations Board?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Abrogated

  • The Supreme Court confined FOIA Exemption 2 to employee relations and human resources records, displacing Schiller's broader protection for internal agency material.

    Milner v. Department of the Navy · Supreme Court of the United States · filed

    Exemption 2, consistent with the plain meaning of the term “personnel rules and practices,” encompasses only records relating to issues of employee relations and human resources. The explosives maps and data requested here do not qualify for withholding under that exemption.
    Read the full opinion on CourtListener →

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