What is the current state of the law on balancing analysis under the Freedom of Information Act?

This court has generally required only minimal evidence that a trial court undertook the balancing analysis required by FREs 403 and 609. In United States v. Portillo, 633 F.2d 1313, 1322-23 (9th Cir.1980), cert. denied, 450 U.S. 1043 (1981), for example, the court upheld the introduction of impeachment evidence when the district judge simply stated that he had balanced the interests and refused to admit evidence of some of the defendant's convictions. In United States v. Field, 625 F.2d 862, 872 n. 6 (9th Cir.1980), the court found that a district judge's decision to exclude one of the defendant's convictions "amply indicates that he was engaged in the process of balancing."