Court opinion issued Jan. 22, 2016
Shapiro v. U.S. Dep't of Justice (D.D.C.) -- denying the parties' summary judgment motions in case involving various documents that the FBI creates while processing FOIA requests, namely search slips, processing notes, and case evaluation forms. Notably, the court rejected the FBI's policy of using Exemption 7(E) to withhold search slips and processing notes generated in response to FOIA requests submitted in the past 25 years for information contained in investigative files. The court further held that the FBI could not categorically withhold case evaluation forms under Exemption 2, but that it could redact the names of individual analysts under Exemption 6.
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