Kilmer v. U.S. Customs & Border Prot. (D.D.C.) -- on renewed summary judgment, ruling that: (1) CBP adequately addressed the court’s earlier concerns regarding the agency’s search for certain communications about the ‘Women’s March” in 2017; and (2) CBP properly withheld records pursuant to Exemptions 5 (deliberative process privilege), 6, 7(C), and 7(E). In reaching its decision, the court rejected plaintiff’s argument that because CBP had certain enforcement powers, the agency’s search and withholdings should be reviewed under a “strict scrutiny” standard.

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