Rocky Mountain Wild v. BLM (D. Colo.) -- finding that: (1) Bureau of Land Management’s supplemental filings established that agency had properly relied on Exemption 5’s deliberative process privilege and met the foreseeable harm standard with respect to withheld records concerning a field office’s amendment of its “Resource Management Plan”; (2) BLM’s supplemental search, which yielded additional responsive records, was adequate; and (3) BLM properly relied on Exemption 6 to redact two newly discovered pages, but it failed to explain how Exemption 5 redactions on one page met the foreseeable harm standard.

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