Judicial Watch v. DOJ (D.D.C.) -- on renewed summary judgment, ruling that FBI reasonably foresaw that disclosure of certain talking points related to agency’s investigation of Hilary Clinton’s private email server would cause harms protected by Exemption 5’s deliberative process privilege; noting that FBI articulated “the connection between the information at issue . . . and the chilling effect of disclosure, and rejecting plaintiff’s argument that a chilling effect that is “highly likely” is not “reasonably foreseeable.”
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