Nat’l Assoc. of Minority Veterans v. Dep’t of Veterans Affairs (D.D.C.) -- following in camera review, ruling that: (1) agency did not forfeit right to invoke exemptions on renewed summary judgment, because the only issue argued on initial briefing was adequacy of the agency’s search (which located no records); (2) “most—but not all—of the information redacted by the VA could create “a reasonably expected risk” of circumvention of the law if released,” thus warranting agency’s Exemption 7(E) claims; (3) agency’s survey questions and responses fell within the deliberative process privilege, but agency’s general contentions that disclosure would ”stifle” communications and cause “public confusion” failed to meet the foreseeable harm test.
Summaries of all published opinions issued in 2024 are available here. Earlier opinions are available here.