Clervrain v. United States (D. Kan.) -- finding that: (1) Federal Bureau of Prisons properly aggregated plaintiff’s three requests because they sought similar records and were submitted by plaintiff on same day; (2) plaintiff failed to appeal agency’s denial of his fee waiver request and therefore court could not consider it.
Linder v. EOUSA (D.D.C.) -- dismissing case as moot because agency provided plaintiff with all records to which he was entitled for free, as plaintiff expressly requested.
Climate Investigations Ctr. v. Dep’t of Energy (D.D.C.) — concluding that: (1) agency performed reasonable search for records concerning clean-coal technology at Mississippi power plant; (2) agency properly withheld records pursuant to Exemption 4 based on impairment and competitive harm theories; (3) agency properly withheld certain records pursuant to attorney-client privilege, but could not rely on privilege to withhold agency communications that included private company’s counsel; and (4) agency properly relied on deliberative process privilege to withhold disputed records originating from agency headquarters, but did not provide sufficient evidence to permit court to evaluate propriety of withholdings made by agency’s National Energy Technology Laboratory; (5) names of third parties had not been previously disclosed publicly, as court initially found, but agency did not properly perform balancing test of private and public interests required by Exemption 6.
Summaries of all published opinions issued since April 2015 are available here.