Louise Trauma Ctr. v. DHS (D.D.C.) -- dismissing remaining portion of plaintiff’s case after holding that plaintiff’s request for “all records concerning” a DHS research unit was “too amorphous to constitute a valid FOIA request.”
McWatters v. ATF (D.D.C.) -- on renewed summary judgment, finding that ATF properly relied on Exemption 7(C) to withhold portion of a tape recording made by one of the 100 victims of a Rhode Island nightclub fire in 2003; crediting ATF declaration that faint human voices could be heard on the recording and that surviving family of the deceased had privacy interests even if voices could not be attributed to specific victims; further, rejecting plaintiff’s asserted public interest as nothing more “than having the information for its own sake,” similar to case involving the recording of the last minutes of NASA’s Challenger shuttle.
Summaries of all published opinions issued in 2024 are available here. Earlier opinions are available here.