Grand Canyon Trust v. Bernhardt (D.C. Cir.) -- affirming district court’s decision that requester was ineligible for attorney’s fees because its lawsuit did not cause a voluntary or unilateral change in agency’s position; further ruling that the proper standard of review for causation was “clear error,” not de novo. In a concurring opinion, Judge Randolph stated that FOIA’s 2007 amendment did not restore the “catalyst theory” because the amended provision “requires only correlation not causation.”

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