The term 'practical obscurity' first appears in U.S. Dept. of Justice v. Reporters Committee for Freedom of the Press, 489 U.S. 749 (1989). Considering the application of FOIA exemption 7(c) to a rap sheet, the court held that where the subject of a rap s

The term 'practical obscurity' first appears in U.S. Dept. of Justice v. Reporters Committee for Freedom of the Press, 489 U.S. 749 (1989). Considering the application of FOIA exemption 7(c) to a rap sheet, the court held that where the subject of a rap sheet is a private citizen and the information is in the Government's control as a compilation, rather than as a record of what the Government is up to, the privacy interest in maintaining the rap sheet's 'practical obscurity' is always at its apex while the FOIA-based public interest in disclosure is at its nadir. Thus, as a categorical matter, rap sheets are excluded from disclosure by the exemption in such circumstances.