Leopold v. Cent. Intelligence Agency (D.D.C.) — in a case concerning records of how CIA investigates personnel misconduct, concluding that the agency was largely justified in withholding records pursuant to Exemptions 1, 3, 6, 7(C), 7(D), and 7(E); of note, finding that a statutory amendment to the CIA Act was applicable retroactively and allowed the agency to broadly protect its internal operations; further, declining to adopt the Eighth Circuit’s heightened standard, which would have required showing an “actual expectation of harm” from the disclosure of records protected under Exemption 7(E), but noting that the agency met that stricter test regardless.
Long v. Immigration & Customs Enf’t (D.D.C.) — denying the parties’ cross-motions for summary judgment regarding the adequacy of the agency’s search; rejecting the requester’s argument that the agency was obliged to extract the requested information from underlying Enforcement Integrated Database and Integrated Decision Support Database dictionaries, rather than a separate “online data dictionary repository know[] as Matrix,” which consists of content uploaded from the underlying databases’ source code; noting that the agency’s declarant establishes that “Matrix is ‘the current authoritative place for technical documents, such as data dictionaries,’” and the agency “cannot simply query the databases themselves for the data dictionaries as . . . requested,” even if this results in an “imperfect” search; accepting the requester’s other objections about the “omission” of certain specific subsets of information, such as "an “‘ENFORCE’ table subset” and “plain-English translations of codes”; further concluding that the agency failed to “explain its withholding of technical database information” based on exemptions invoked in concurrent litigation.
Informed Consent Action Network v. Health Res. & Servs. Admin. (D.D.C.) — granting the government’s motion for summary judgment; holding that, in a case involving a request for the names of “every employee” of a certain office within the Department of Health and Human Services, the agency properly released “the names of the Director and Deputy Director” while withholding “the names of the 35 employees that worked underneath them” under Exemption 6; noting that “employees in the office have received harassing and threatening emails, voicemails, and text messages,” and therefore have substantial privacy interests at stake, and the requester has not shown that the “public’s interest in knowing the names” of lower level employees would do anything but add “minimal incremental value” to understanding of how the agency “is adjudicating claims for COVID-19 related injuries” or otherwise “spending taxpayer money”; similarly questioning the strength of the asserted public interest in knowing whether the employees’ identities would implicate their qualifications or potential conflicts of interest.
Kleinert v. Bureau of Land Mgmt. (D.D.C.) — denying the requester’s motion for attorney’s fees and costs; concluding the requester was not “eligible” since “[t]he record reflects that the disclosure of the . . . [r]ecords” at issue “resulted from ‘delayed administrative processing,’ not a chance in position prompted by Plaintiff’s lawsuit”; noting also that “[w]hile the agency’s two-year delay in releasing” documents “was undoubtedly the product of repeated mistakes, the record nonetheless shows a good-faith effort to respond.”
Ctr. for Immigration Studies v. U.S. Citizenship & Immigration Servs. (D.D.C.) — denying the government’s motion for summary judgment and granting in part the requester’s cross-motion; holding, in relevant part, that the requester reasonably described the records sought, and the agency’s failure to undertake a search was improper, but reserving judgment on the agency’s claim that the actual search for and processing of potentially responsive records would either be unreasonably burdensome or require the creation or new records; rejecting the agency’s argument that a request for “‘all records sufficient show any and or all the . . . information’ responsive to four distinct inquiries relating to supporters of CHNV parole applicants” is “analogous to [a request] seeking ‘any and all documents and records’ that ‘relate’ to a given subject”; holding further that, insofar as the agency wished to defend any “no responsive records” determination on a subpart of the request at issue, its briefing and declaration were factually “insufficient”; finally, noting the declaration is also insufficient, in part, because it does not explain why certain component offices were “the ones most likely to contain responsive records,” or whether any other offices were locations “where record were reasonably likely to be found.”
Citizens for Responsibility & Ethics in Wash. v. Dep’t of Justice (D.D.C.) — ruling that plaintiff’s challenge to DOJ’s categorical withholding of records about former Congressman Matt Gaetz on privacy grounds was moot because DOJ began processing and producing records after briefing commenced; further ruling, in most relevant part, that plaintiff failed to show that DOJ maintained a broad, unlawful policy of issuing Glomar responses to requests about third-party investigations, but noting potentially erroneous practices of the Criminal Division and FBI that could support narrower policy-or-practice claims and denying both parties’ summary judgment motions on this count.
Summaries of published opinions issued in 2026 are available here. Earlier opinions are available for 2025, 2024, and from 2015 to 2023.
