Smart-Tek Servs. v. IRS (9th Cir.) (unpublished) -- affirming district court’s decision that IRS performed adequate search for plaintiffs’ employment, corporate, and partnership tax returns, and holding that records of alter ego companies—which were commingled with plaintiffs’ records during FOIA processing and withheld by IRS under Exemption 3—were not responsive to plaintiffs’ requests.
WP Co. v. SBA (D.D.C.) -- determining that SBA failed to demonstrate that Exemptions 4 and 6 protected the names of loan recipients and amounts borrowed from the Paycheck Protection Program and Economic Disaster Loans program. In reaching its decision, the court noted that the SBA had notified loan applicants that such information would be disclosed upon request.
Summaries of all published opinions issued since April 2015 are available here.