FOIA Advisor

Court opinions issued Mar. 18, 2025

Court Opinions (2025)Allan BlutsteinComment

Berlant v. U.S. Election Comm’n (D. Oregon) -- denying pro se plaintiff’s motion for reconsideration because it was filed one day too late under Federal Rule of Civil Procedure 59(e), and her simultaneously filed appeal with the Ninth Circuit deprived the court of jurisdiction to entertain plaintiff’s motion under Rule 60; alternatively, plaintiff’s motion failed because she identified no new evidence, clear error, or intervening change in the law.

Emesowum v. NSA (D. Md.) -- in case concerning existence of video showing vehicles arriving at agency’s front gate, denying agency’s motion to dismiss because NSA had not (yet) provided adequate documentation to support its contention that the video was “routinely deleted before the NSA could practicably retrieve it.”; further, dismissing plaintiff’s claim for punitive damages and dismissing an individual NSA employee as a party.

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