FOIA Advisor

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Court opinions issued June 18, 2019

McGehee v. DOJ (D.D.C.) -- denying plaintiff’s motion to reconsider summary judgment ruling in case concerning FBI’s investigation of Jonestown massacre, because plaintiff failed to show change of controlling law, availability of new evidence, or clear error or manifest injustice, as required by FRCP 59(e).

Wolk Law Firm v. NTSB (E.D. Pa.) -- holding that agency properly relied on Exemptions 2, 3, 4, 5, and 6 to withhold records concerning multiple accident investigations, including cell phone video of airplane’s cockpit. The court further held that FOIA did not compel production of actual airplane wreckage, as it falls outside meaning of “agency record.”

Summaries of all published opinions issued since April 2015 are available here.