FOIA Advisor

Court opinions issued Aug. 7-Aug. 11, 2017

Court Opinions (2015-2023)Allan BlutsteinComment

Aug. 11, 2017

Clemente v. FBI (D.C. Cir.) -- affirming district court's decision that FBI conducted a reasonable search for records concerning mob informant Gregory Scarpa and that disputed records met law enforcement enforcement threshold; further finding that court did not abuse discretion by denying interim attorney's fees or by dismissing case after plaintiff missed filing deadlines. 

Aug. 8, 2017

Judicial Watch v. U.S. Dep't of State (D.D.C.) -- concluding that agency's search for former Secretary of State Hillary Clinton's e-mails related to Benghazi attack was inadequate because agency neglected to search the "state.gov" accounts of aides Huma Abedin, Cheryl Mills, and Jacob Sullivan. 

Gahagan v. U.S. Citizenship & Immigration Servs. (E.D. La.) -- ruling that agency's supplemental declaration established that disputed records were properly withheld pursuant to Exemption 5. 

Burke v. DHS (D.D.C.) -- ruling that Transportation Security Agency performed an adequate search for travel records concerning plaintiff and his family.  

Aug. 7, 2017

McKinley v. FDIC (D.D.C.) -- deciding that agency failed to show that withheld records concerning Citibank were properly withheld under Exemptions 4, 5, or 8, and ordering agency to submit revised Vaughn Index and/or declarations.

Shapiro v. CIA (D.D.C.) -- finding that FBI properly withheld certain records regarding Nelson Mandela under deliberative process privilege, and that agency properly excluded certain pages as non-responsive because they neither mention Nelson Mandela nor put the relevant pages in context.

Summaries of all opinions issued since April 2015 available here.