their own refuge from a sensation-seeking culture for their own peace of mind and tranquility, not for the sake of the deceased.” Id. at 166, 124 S.Ct. 1570. Accordingly, contrary to PLN’s contention that any privacy interest of Estrella’s family is derivative of Estrella’s own privacy interest, family members’ privacy interests under FOIA are independent interests. Estrella’s status as a prisoner only has the potential to affect his own, and not his family’s, privacy interests. Estrella’s family did not waive their privacy interests in the video and photographs as a result of the government’s use of these materials at the Sablans’ trials. The government cannot waive individuals’ privacy interests under FOIA. See Sherman v. U.S. Dep’t of Army, 244 F.3d 357, 364 & n. 12 (5th Cir.2001) (<HOLDING>). As such, neither the government’s conduct in
holding that the government cannot waive foia exemption 6 on behalf of the individual whose privacy interests the exemption protects holding the governments prior disclosure of requested information could not waive individuals privacy interests under exemption 6 and collecting cases involving exemption 7c holding that there is no need to consider exemption 6 separately if information was compiled for law enforcement purposes because exemption 7c constitutes broader protection so any information falling under exemption 6 is covered by exemption 7c holding act qualifies as exemption statute under exemption 3 holding a debtors claim for loss of consortium to be entitled to an exemption under the oklahoma exemption statute and collecting other bankruptcy decisions recognizing a debtor spouses loss of consortium as the basis for allowing an exemption under federal and various state exemption statutes