FOIA Advisor

Court opinion issued May 16, 2024

Court Opinions (2024)Allan BlutsteinComment

Guarascio v. FBI (D.D.C.) -- on renewed summary judgment uncontested by plaintiff, ruling that: (1) FBI established that it performed a reasonable search for records related to plaintiff’s conviction for manufacturing child pornography, in part, by averring that it “searched all locations and files reasonably likely to contain responsive records, and there is no basis for the FBI to conclude that a search elsewhere would reasonably be expected to locate responsive records subject to the FOIA”; and (2) FBI properly relied on Exemption 7(D) to withheld certain records from a file received from the North Carolina State Bureau of Investigation, which contained “clear indicators,” including express markings, that the material was confidential.

Summaries of all published opinions issued in 2024 are available here. Earlier opinions are available here.