Wonder v. Dep’t of the Army Office of Gen. Counsel (D.D.C.) -- concluding that: (1) plaintiff’s failure to exhaust his 2012 and 2014 requests for a legal memo concerning his security clearance did not bar plaintiff’s duplicate 2022 request (which was fully exhausted), rejecting government’s exhaustion position as “a harsh sanction unsupported by statute, precedent, or logic”; and (2) Army properly withheld the disputed memo pursuant to Exemption 5’s attorney-client privilege and it satisfied statute’s foreseeable harm requirement.
Summaries of all published opinions issued in 2024 are available here. Earlier opinions are available here.