In the case of United States Department of Justice v. Reporters Committee for Freedom of the Press, 1988, the Supreme Court ruled that under exemption 7(C) in the Freedom of Information Act (FOIA), an individual's right to privacy outweighs public interest when it comes to disclosing criminal records held by federal agencies. The Reporters Committee and CBS had requested access to a 'rap sheet' compiled by FBI about four members involved in organized crime who were connected with a Pennsylvania company holding defense contracts. The court concluded that such disclosure would constitute an unwarranted invasion of personal privacy as there was no significant public interest served by revealing this information since it did not shed light on any agency’s performance or activities.

In the dissenting opinion for United States Department of Justice v. Reporters Committee for Freedom of the Press, Justice Blackmun argued that the majority's decision was too narrow in its interpretation of privacy rights under FOIA exemptions. He contended that this ruling could potentially undermine transparency and accountability within government agencies by allowing them to withhold information from public scrutiny based on an overly broad definition of personal privacy. Furthermore, he expressed concern over how this decision might impact journalists' ability to access vital information necessary for investigative reporting, thereby hindering their role as watchdogs holding government accountable to the public. In essence, his dissent emphasized a need for balance between individual privacy rights and societal interest in open governance.