Argued October 24, 2024 Decided January 24, 2025

No. 23-5236

HUMAN RIGHTS DEFENSE CENTER, APPELLANT

v.

UNITED STATES PARK POLICE, APPELLEE

Appeal from the United States District Court for the District of Columbia (No. 1:19-cv-01502)

Jim Davy argued the cause for appellant. With him on the briefs was Deborah M. Golden.

Ryan P. Mulvey was on the brief for amicus curiae Americans for Prosperity Foundation in support of appellant.

Bruce D. Brown, Katie Townsend, and Adam A. Marshall were on the brief for amici curiae Reporters Committee for Freedom of the Press, et al. in support of appellant.

Keisha James was on the brief for amicus curiae National Police Accountability Project in support of appellant. 2 Maxwell A. Baldi, Attorney, U.S. Department of Justice, argued the cause for appellee. With him on the brief were Brian M. Boynton, Principal Deputy Assistant Attorney General, Matthew M. Graves, U.S. Attorney, and Mark B. Stern, Attorney.

Before: PILLARD and GARCIA, Circuit Judges, and GINSBURG, Senior Circuit Judge.

Opinion for the Court filed by Circuit Judge PILLARD.

PILLARD, Circuit Judge: The Human Rights Defense Center, a non-profit news and advocacy organization focused on incarcerated people in the United States, filed a Freedom of Information Act request for information about legal actions against the United States Park Police. After the Park Police failed to respond to the request within the statutory period, Human Rights Defense Center brought this FOIA lawsuit. The Park Police eventually produced documents responsive to the FOIA request but withheld the names of officers involved in three tort settlements. It based those withholdings on FOIA Exemption 6, which protects from disclosure information that would constitute a “clearly unwarranted invasion of personal privacy.” 5 U.S.C. § 552(b)(6). The Center challenges that privacy assertion. The Park Police’s document productions created a separate legal dispute by inadvertently disclosing information the agency had intended to withhold. In documents referencing cases by name, it failed to fully redact the names of one employment discrimination claimant and one tort claimant. The Park Police argued that the Human Rights Defense Center should be barred from using or disseminating the inadvertently disclosed information. The Center disagrees.

The district court ruled that the Park Police correctly withheld the officer names under Exemption 6. The court then 3 invoked its inherent authority to manage judicial proceedings as justification to issue a clawback order for the erroneously produced names. Those rulings were erroneous. By putting forth generic and conclusory justifications for its withholdings, the Park Police failed to satisfy its burden under Exemption 6 and the FOIA Improvement Act to show that release of the officer names would implicate a substantial privacy interest. And the district court’s non-statutory remedy for the Park Police’s inadvertent disclosures was not a valid exercise of inherent judicial authority because its primary purpose was to fill a perceived gap in the FOIA statute, not to protect the exercise of any core judicial authority. We therefore vacate the clawback order and remand for the release of the non-exempt officer names.

I.

A.

The Freedom of Information Act “commands that government agencies, ‘upon any request for records . . . shall make the records promptly available to any person.’” Reps. Comm. for Freedom of the Press v. FBI, 3 F.4th 350, 357 (D.C. Cir. 2021) (quoting 5 U.S.C. § 552(a)(3)). Agencies may withhold from disclosure information that falls within one of the Act’s nine enumerated