FOIA Advisor

Court opinions issued Apr. 28, 2020

Court Opinions (2015-2023)Allan BlutsteinComment

Scott v. IRS (S.D. Fla.) denying plaintiff’s request for discovery because plaintiff failed to follow applicable discovery rules, failed to show any bad faith by the agency, and the request was overbroad, vague in part, and fell outside scope of limited discovery sometimes permitted in FOIA cases.

Zavalunov v. BOP (M.D. Pa.) -- ruling that Federal Bureau of Prisons performed adequate search for requested ICE detainer and properly redacted third party information pursuant to Exemptions 6 and 7(C).

Strahan v. NOAA (D. N.H.) -- concluding that plaintiff failed to exhaust his administrative remedies for six of seven of his requests, and that agency was not required to create excel spreadsheet containing information that was publicly available on website.

Colgan v. DOJ (D.D.C.) -- remanding matter to FBI after finding that: (1) agency failed to perform reasonable search in response to plaintiff’s 30-part request; and (2) agency’s Vaughn Index lacked sufficient detail to permit review of claimed exemptions and sampled documents had 64 percent error rate.

DBW Partners v. USPS (D.D.C.) -- determining that USPS properly relied on Exemption 3 in conjunction with the Postal Reorganization Act to withhold large portions of Inspector General report concerning USPS’s resellers program and negotiated service agreements, but ordering release of certain portions after performing in camera review.

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