The implementation of the Freedom of Information Act has resulted in an era of transparent public administration by allowing disclosure on many parts of the public administration area. Every citizen has the right to request disclosure. The right to disclosure includes not only the specific right to disclosure as to matters of personal interests, but also the general right to disclosure on general matters of public interests. Accordingly, the disclosure scheme is now being used to guarantee the public’s meaningful involvement in public administration. Its usefulness is being highlighted by the phenomenon that people have an increasing amount of interest in local governments’ expense accounts, including entertainment expenses.
The public shows interests in expense accounts of the leaders of local governments, because such accounts show how the leaders are performing their tasks. The request to disclosure of expense accounts implicates three issues. First, the issues if whether a citizen, who has no direct personal interests at stake, has standing to request such disclosure. The second issue is whether the local government heads’ expense accounts are properly subject to such a request. The last issue is, assuming that they are subject to disclosure, how to cope with the situation where undiscoverable information such as personal information is mixed with discoverable information.
This case recognizes that plaintiff has an legal interest to overturn the refusal and to compel disclosure in freedom of information proceedings, and reaffirms the previous holdings on the standard to determine when disclosure of personal information is necessary for public interests. It is also noteworthy for its holding that the personal information contained in the information on expense accounts is not discoverable as to protect the individual’s privacy.
This case is also significant in that it specifically articulates the methods as to partial disclosure. As personal information and trade secrets are scattered through the expense account ledgers, there is a strong need for express identification of information not subject to disclosure for proper executions of the court orders. This case satisfies such a need.