Ctr. for Immigration Studies v. USCIS (D.D.C.) — after in camera review, holding that USCIS properly withheld an internal policy memo concerning a “temporal tweak” to the Temporary Protected Status designation of Haiti under Exemption 5 and the deliberative-process privilege; describing the memo as a “recommendary proposal”; rejecting the requester’s “adoption” argument because the factual record did not suggest “an express choice to use a deliberative document as a source of agency guidance”; similarly rejecting the requester’s “working law” argument given the nature of the advisory memorandum at issue; concluding the agency satisfied the foreseeable-harm standard because “release would chill candid speech about sensitive issues of foreign policy.”

Energy & Policy Inst. v. Tenn. Valley Auth. (E.D. Tenn.) — ruling that plaintiff was ineligible for attorney’s fees and litigation costs totaling $150k, notwithstanding the agency’s release of previously withheld records after the litigation started; accepting TVA’s argument that a business submitter, not the agency, changed its position on the confidential nature of certain records that had been withheld under Exemption 4; rejecting plaintiff’s argument that the “buck stops with TVA” with respect to withholdings, noting that the “statute expressly envisions cooperation of non-agency parties.”

Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.