FOIA Advisor

Court opinions issued July 5, 2017

Court Opinions (2017)Allan BlutsteinComment

Trucept v. IRS (S.D. Cal.) -- ruling that: (1) IRS failed to demonstrate that it performed reasonable search for responsive records; (2) IRS properly withheld records pursuant to Exemptions 5, 7(A), and 7(D); (3) IRS failed to address whether "Risk Score" withheld under Exemption 7(E) was technique unknown to public; and (4)  judgment would be reserved as to Exemptions 3, 6, and 7(C) until record was further developed.

Frost v. Wilkinson (N.D. Cal.) -- dismissing complaint because plaintiff improperly named an employee of the Executive Office for United States Attorneys as the defendant instead of the agency; stating in dicta that agency appeared to have conducted adequate search for records, which was sole issue in dispute.

Summaries of all opinions issued since April 2015 available here.