Rocky Mountain Wild, Inc. v. U.S. Forest Serv. (10th Cir.) -- affirming district court’s decision and finding that: (1) plaintiff waived argument that Vaughn Index was insufficient; (2) agency performed reasonable search for voluminous records concerning proposed highway project; (3) agency properly withheld records pursuant to Exemption 5 and demonstrated prospective harm, but declining to hold that the foreseeable harm provision imposed a “heightened burden”; and (4) district court properly ordered plaintiff to return two documents that agency accidentally disclosed to plaintiff without redaction, even though another organization subsequently posted the documents online.

Wright v. HHS (D.D.C.) -- denying government’s motion to dismiss case concerning COVID-19 vaccine safety records, because agency ignored Departmental regulation to contact requester and explain why it found one of his requests to be overbroad and not reasonably described.

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