In the recent District of Columbia Court of Appeals case of Forsham v. Califano, the definition of "agency records" was equated with the definition of "agency" under the Freedom of Information Act (FOIA). The purpose of this Comment is to examine the propriety and impact of such a definition of "agency records" in light of the people's right to know what their government is doing, using as a focal point the controversy that arose in Forsham v. Califano.
Note, Applying the Freedom of Information Act in the Area of Federal Grant Law: Exploring an Unknown Entity, 27 Clev. St. L. Rev. 294 (1978)