FOIA Advisor

Court Opinions (2025)

Court opinion issued Mar. 30, 2025

Court Opinions (2025)Allan BlutsteinComment

Farris v. Garland (D.D.C.) -- determining that: (1) the Executive Office for U.S. Attorneys conducted a reasonable search for certain records related to plaintiff’s conviction for drug trafficking, and it had no obligation to obtain records maintained by other federal or local agencies; (2) government properly withheld certain information from investigative “DEA 6 Reports” pursuant to Exemptions 7(C), 7(D), and 7(E).

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

Court opinion issued Mar. 28, 2025

Court Opinions (2025)Allan BlutsteinComment

Ctr. for Biological Diversity v. U.S. Forest Serv. (D.D.C.) -- finding that: (1) federal contractor’s appraisal of a land exchange between the government and defendant-intervenor, a private mining company, qualified as an “agency record” because the agency “constructively controlled” the appraisal based on the four-factor test set forth in Burka v. HHS, 87 F.3d 508 (D.C. Cir. 1996); using the same test, finding that the contractor’s documents containing data underlying the appraisal were not agency records; (2) agency justified withholding information that would result in foreseeable economic harm to defendant-intervenor, but offered only inadmissible hearsay as to whether withheld information that would result in foreseeable harms to the appraiser and third-party experts’ business interests; (3) agency properly invoked Exemption 5’s deliberative process privilege to withhold the appraisal, summary, and technical report as pre-decisional and deliberative, but rejecting the reasonableness of the harms foreseen by the agency; and (4) agency’s segregability analysis was insufficient because the agency inconsistently processed an appraisal summary and a technical report.

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

Court opinions issued Mar. 24-26, 2025

Court Opinions (2025)Ryan MulveyComment

Mar. 24, 2025

Cohodes v. Dep’t of Justice (N.D. Cal.) — after awarding $180,808.50 in attorney’s fees, and following supplemental briefing precipitated by plaintiff having “estimated [certain] fees in the initial fees motion and document[ing] them only in the reply,” granting plaintiff an additional $73,948.95 “in fees for [its] fees motion” because “the hourly rates and hours spent are reasonable”; rejecting the government’s request to apply an across-the-board reduction; in total, awarding the requester $254,757.45.

Basey v. Dep’t of Justice (D. Alaska) — holding the agency conducted a reasonable search given the “context of [the requester’s] broad request”; describing the execution of searches in the components “most likely to have responsive records,” as well as the FBI’s separate search as recipient of a referral from EOUSA; noting the requester’s “allegations of bad faith rest on innuendo” and rest on “purely speculative claims about the existence and discoverability of other documents”; holding also that the government properly applied: (1) Exemption 3, in conjunction with the Child Victims’ & Child Witnesses’ Rights Act, 18 U.S.C. § 3509(d), to withhold “‘interviews of a minor victim and explicit media involving’ child sexual abuse,” (2) Exemption 5 and the deliberative-process privilege, together with Exemptions 6 and 7(C), to withhold records pertaining to interviews of victims abused by the requester, and (3) Exemption 7(E) to withhold records concerning the FBI’s Computer Analysis Response Team and Cyber Division’s Innocent Images National Initiative Program.

March 25, 2025

Heritage Found. v. Dep’t of Justice (D.D.C.) — in a case where the parties contested the proper meaning of the term “request,” denying the government’s motion for summary judgment and adopting the plaintiff’s proposed interpretation; holding that the FBI improperly split-up the plaintiff’s three-item FOIA request into three separate “requests”; explaining that, despite the agency having issued timely adverse determinations on two of the three parts, the requester was not required to exhaust administrative remedies as to those denials (and the separate denial of a fee waiver) before filing suit on the entirety of its submission after the agency failed to provide a timely response to the third item; suggesting that common usage, relevant caselaw, and statutory context all point to “request” best “refer[ring] to an overall FOIA submission,” rather than individual parts of a multi-item “submission”; noting that, while FOIA provides explicit authority to aggregate or consolidate distinct requests, there is no mention of splitting-up a request; expressing skepticism towards the agency’s contention that ruling for the plaintiff would “allow requesters to strategically circumvent the administrative appeal process.”

Evans v. Cent. Intelligence Agency (D.D.C.) — granting the government’s motion for summary judgment and holding that (1) the CIA’s search for records was adequate, (2) it properly issued a Glomar response pursuant to Exemption 1 as to a portion of the request, and (3) the plaintiff failed to exhaust administrative remedies with respect to the CIA’s use of Glomar with Exemption 3; explaining the plaintiff offered only “mere speculation” about “uncovered documents,” and the agency was not required to “list each system it searched, as opposed to the categories or types of systems”; rejecting the plaintiff’s arguments on the Glomar front, which focused on the level of detail in the agency’s supporting declaration; noting the requester failed to raise any objection in his appeal about the use of Exemption 3 with Glomar.

March 26, 2025

Energy Pol’y Advocates v. Sec. & Exch. Comm’n (D.D.C.) — granting, in part, the government’s motion for summary judgment; holding the agency properly used Exemption 5, in conjunction with the deliberative-process privilege, to withhold calendar entries of a former SEC Chairman; yet concluding that, because many entries in the agency’s Vaughn index lacked adequate specificity and failed to “identify the subject of policy under consideration and instead refer[red] only to policymaking in general,” the agency had not met its burden to justify the withholding of certain e-mail communications between the White House, former SEC Chairman, and senior agency officials; ordering in camera review of the e-mail records; deferring consideration of the agency’s satisfaction of the foreseeable-harm standard for the e-mails, but holding the agency’s argument vis-à-vis the calendar entries was adequate.

Bader Family Found. v. Equal Emp’t Opportunity Comm’n (D.D.C.) — denying the government’s motion for summary judgment and holding various parts of plaintiff’s request were “reasonably described”; explaining two of the request items in dispute “are not vague and have only one reasonable interpretation,” the agency “has not put forward a sufficiently detailed declaration explaining why . . . [responsive] records are difficult to locate,” and “the agency’s declarations do not sufficiently explain how the post-search efforts . . . would be overly burdensome”; similarly, with respect to the third item in dispute, concluding the agency “can reasonably construe [it] without” further clarification or defined terms, it “cannot definitively say [based on the record] . . . that searching for . . . text messages would be unreasonably burdensome,” and it “has not provided sufficient evidence” about “overly burdensome post-search efforts.”

Judicial Watch v. Dep’t of State (D.D.C.) — granting the agency’s motion to dismiss and holding that plaintiff’s request did not “‘reasonably describe’ the records sought” because it “uses vague words and descriptions,” including the phrase “all records related to”; emphasizing, at the same time, that “[t]here is no bright-line rule barring FOIA requesters from using the phrase “related to,” and a court’s analysis must focus on “whether the request is otherwise so ‘unusually specific’ that it still manages to satisfy FOIA’s reasonable-description requirement”; noting the plaintiff’s request “lacks any custodial limitation and does not specify the type of records sought”; querying “what . . . [the] other ‘related’ records [are] that the agency must look for if the categories of records identified in the latter part of the request are not sufficient.”

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

Court opinions issued Mar. 19-21, 2025

Court Opinions (2025)Ryan MulveyComment

Mar. 19, 2025

Citizens for Responsibility & Ethics in Wash. v. U.S. DOGE Serv. (D.D.C.) — denying the government’s motion for reconsideration of a prior preliminary-injunction ruling that held U.S. DOGE Service was likely an “agency” for FOIA purposes, in large part, because the government’s “arguments could all have been raised during the last round of briefing” and “none of them provides a basis for reconsideration”; acknowledging, nonetheless, that “it would be preferable . . . to review the question of whether [DOGE] is subject to the FOIA on the merits based on a more complete record,” and therefore inviting the requester to file a motion for limited discovery under Federal Rule of Civil Procedure 56(d); expressing doubt that the irreparable-harm analysis underlying the Court’s preliminary injunction ruling was erroneous; continuing to point to public statements by President Trump and Elon Musk, as well as press reports, that cast doubt on the government’s various factual claims. [RPM: FOIA Advisor previously reported on this decision when it first issued.]

U.S. Right to Know v. Dep’t of Def. (N.D. Cal.) — granting in party and denying in part the plaintiff’s motion for attorney’s fees; noting the government did “not contest that Plaintiff is eligible to receive an award of fees and costs”; on the question of entitlement, concluding that: (1) the public interest favors the award, as the records, which pertain to COVID-19, could help reveal “‘possible politicization of agency decisionmaking’”; (2) the plaintiff, as a non-profit organization, had no commercial interest in the responsive records; and (3) the agency acted unreasonably by failing to comply with statutory deadlines, or to communicate with the plaintiff “for over two years until after suit was commenced,” and by significantly over-redacting the responsive records in the first instance without any “colorable basis under the law”; ultimately awarding “$74,312.88 in attorneys fees and $688.96 in costs,” or roughly $10,000 less than what plaintiff asked for, after rejecting recovery for: (1) certain administrative tasks, like fixing access problems to USAfx or other “purely clerical tasks,” (2) internal attorney communications that were vaguely described in the ’ fee motion and supporting declarations, (3) pro hac vice fees, and (4) costs related to “expert declarations.”

Mar. 20, 2025

Simmons v. Dep’t of State (D.D.C.) — denying an aggrieved, former State Department employee’s motion for attorney fees in light of her failure to demonstrate under the “catalyst theory” how she “substantially prevailed,” and was therefore eligible for fee recovery; specifically, noting the requester failed to show “this litigation caused [the agency] to comply with her FOIA and Privacy Act requests”; noting also the agency had “immediately started processing records and made several pre-litigation productions”; relatedly concluding the requester “fail[ed] to rebuff evidence that [any] delayed ‘disclosure result[ed] not from the suit but from delayed administrative processing.’”

Leopold v. Dep’t of Justice (D.D.C.) — on remand from the D.C. Circuit for a “third round of summary judgment,” denying the parties’ cross-motions for summary judgment regarding withholding under Exemption 8 of a redacted version of an independent monitor’s report detailing HSBC’s compliance with a deferred prosecution agreement, specifically with respect to the justification for continued non-disclosure under the foreseeable-harm standard; ruling that, while “Exemption 8’s broader protections . . . related to financial institutions apply,” in camera review of the monitor report is needed to resolve the case; noting, inter alia, that another judge “found not harm in disclosing a redacted version,” and that DOJ’s own filings suggest “portions of the . . . [r]eport might be . . . released with minimal risk of harm.”

Crandell v. Nat’l Archives & Records Admin. (4th Cir.) (unpublished) — affirming dismissal of FOIA lawsuit, where the requester failed to exhaust administrative remedies and failed also to demonstrate that the records he had requested “still existed”; modifying the district court’s ruling, however, by ordering the dismissal to be without prejudice.

Mar. 21, 2025

Wiggins v. Dep’t of Justice (D.D.C.) — granting in part and denying in part the government’s motion for summary judgment; holding that the agency conducted an adequate search where it explained the custodial locations searched and the search terms utilized; noting that plaintiff proffered no “evidence” to support its “assertion of missing records”; holding also that the agency failed to offer adequate explanation for its use of Exemption 5 to withhold “undated and unsigned proposed amended jury instructions,” as well as other “unsigned” and either “undated” or “partially dated” litigation documents, including e-mail records between DOJ personnel “regarding the prosecution of plaintiff and the co-defendant’s criminal cases”; explaining that “EOUSA’s cryptic description” for the various “document[s] or categor[ies] of documents” does not establish their deliberative nature; noting also the agency’s “generic assertions of harm to internal discussions . . . parroted throughout the Vaugh index”; with respect to Exemption 7(C), holding that the agency properly redacted “the names and other identifying information of third-party individuals, including Eastern District employees, third-party witnesses, and co-defendants”; finally, concluding that “EOUSA has not properly justified withholding fifty-one sealed pages,” as it “offered no evidence”; directing the government to “supplement the record” and, if appropriate after re-processing, to “move again for dispositive relief.”

Ctr. for Medical Progress v. Dep’t of Health & Human Servs. (D.D.C.) — granting the agency’s motion for summary judgment and denying the plaintiff’s cross-motion; holding, firstly, that the agency “properly determined the scope of the plaintiff’s FOIA request,” which sought a “specific set of documents” about “grant applications,” especially in light of the plaintiff’s oral and written clarifications upon request from the agency, as well as its agreement to narrow its request post-submission; holding further that the agency conducted an adequate search; noting that “[b]eyond the contract records” that were properly beyond the scope of the request, “the plaintiff provide[d] no further basis to challenge the good faith basis” afforded to the agency’s supporting declarations.

Am. Property Locators, Inc. v. Customs & Border Prot. (D.D.C.) — in a case involving a commercial-use FOIA request for records about stale checks from CPB, granting the agency’s motion to dismiss and approving its inclusion in a fee estimate of expenses related to carrying out the “business submitter process”; explaining that CBP maintains a special process for notifying “submitters” of “commercial information” so that they can object to disclosure of their information under the FOIA, and that the agency has treated “Limited Payability (stale dated check) records” as triggering this “process”; declining to adopt the government’s recommendation to either apply arbitrary-and-capricious review or Auer deference in lieu of the FOIA’s default de novo review standard; holding that CPB provided a “‘reasonable, non-obstructionist explanation’ . . . for applying the business submitter process” based on its published regulations, and that it appropriately assumed responsive records would “encompass emails between CBP and business submitters regarding the original commercial transaction, the status of payee checks, the occurrence of novel financial transactions, and/or bank account information”; rejecting plaintiff’s argument that any possible exceptions to the business-submitter process applied; noting the “process itself is reasonable” as it “‘give[s] effect to Exemption 4,” among other things; finding no basis in the record to doubt the actual fee estimate of $738; finally, concluding that the requester failed to exhaust by “pay[ing] the required fees before suing the challenge the substance of [its] FOIA request.”

Rhodes v. Internal Revenue Serv. (N.D. Ala.) — granting the agency’s motion to dismiss for failure to exhaust administrative remedies; rejecting the requester’s apparent argument, based on the language of his complaint, that “there were no administrative remedies to be exhausted”; rejecting also the requester’s suggestion that the IRS’s determination letter was “insufficient to trigger a duty to exhaust his claims” because it “did not communicate the scope of the documents it withheld” by including a “privilege log.”

Jackson v. Internal Revenue Serv. (N.D. Ala.) — in an almost word-for-word, identical opinion to that published above in Rhodes, granting the agency’s motion to dismiss for failure to exhaust administrative remedies.

Cahill v. Dep’t of Commerce (D.D.C.) — granting the agency’s motion to dismiss for mootness where a pro se requester admitted the agency “finally complied” with his request prior to filing suit; denying also the requester’s motion for costs because the “Department turned over the video [at issue] without a court order, written agreement, or consent decree,” the record was “outside the scope of [the requester’s] FOIA request,” and “the Department would have been able to meritoriously defend its denial of . . . [the] request by arguing that [the requester] had failed to exhaust his administrative remedies.”

Citizens for Responsibility & Ethics in Wash. v. Dep’t of Justice (D.D.C.) — in a case seeking access to records related to the “now-closed criminal investigation of former Congressman Matt Gaetz,” in which the requester also pleaded policy-and-practice claims related to the use of Glomar responses and categorical withholdings under Exemptions 6 and 7(C), granting in party and denying in part the government’s motion to dismiss; with respect to allegations about an unlawful Glomar-response policy, holding that CREW can appropriately “aggregate” evidence about the behavior of multiple “components within a larger agency” to sustain its claim; noting, in that respect, how “CREW has identified six instances of potentially violative conduct across four DOJ components,” that this “is numerically sufficient to show a pattern for purposes of a motion to dismiss,” that there is sufficient relation between the examples to suggest a “consistent policy,” and that CREW has otherwise “plead sufficient facts to suggest” the ostensible policy is unlawful; holding also, by contrast, that CREW’s policy-or-practice claim about Exemption 6/7(C) responses must be dismissed because DOJ’s “responses to CREW’s three requests were not uniform,” and therefore undercut any theory that they did not reflect “case-by-case analysis.”

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

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.

Court opinions issued Mar. 14, 2025

Court Opinions (2025)Ryan MulveyComment

Finders Keepers USA, LLC v. Dep’t of Justice (D.D.C.) — on renewed cross-motions for summary judgment, granting in part and denying in part each party’s motion; on the question of search adequacy, (1) finding that the FBI’s chosen search terms were “reasonably calculated to uncover all relevant documents,” (2) rejecting the agency’s cut-off date (i.e., the date of its initial search) as unreasonable because it “should have looked for records through the date of its second search,” and (3) again identifying deficiencies in the FBI’s averments that it searched all files likely to contain responsive material, given the facts of the case and prior proceedings; similarly ruling that the search for certain DVD videos was reasonable; deciding that “a genuine dispute of fact” exists as to whether the FBI was required to produce all versions of a particular operational plan; and, finally, rejecting once again the FBI’s invocation of Exemption 7(E) for failure to identify the risks of circumvention of the law, and for failure to satisfy the foreseeable-harm standard; ordering in camera review and further proceedings.

Francis v. Internal Revenue Serv. (D.D.C.) — granting the agency’s combined motions to dismiss and for summary judgment; dismissing as moot several counts in the complaint because the IRS located responsive records and released them in full, and there was no further challenge to the adequacy of the relevant searches; concluding that, with respect to another count, the requester failed to exhaust administrative remedies by admittedly failing to file an appeal before initiating the lawsuit; rejecting another two counts as pertaining to improper or invalid FOIA requests that “sought information and not records”; and, finally, ruling the IRS conducted an adequate search for all remaining counts, and rejecting the requester’s arguments that the agency “acted in bad faith through its false and misleading representations.”

Tsai v. United States (D.D.C.) — in relevant part, granting the IRS’s motion for summary judgment and holding that the agency conducted an adequate search; noting an apparent “gap between what [the requester] had actually requested and what he . . . intended to request,” but accepting the agency’s arguments that post-submission modification or enlargement of the scope of the request was improper given its “four-corners”; declining to strike the agency’s supporting declaration for lack of personal knowledge because, “[i]n the FOIA context, ‘declarants are not required to have personal knowledge of the search itself, but rather ‘personal knowledge of the procedures used in handling [a FOIA] request and familiarity with the documents in question.’”

White v. Dep’t of Agric. (E.D. Okla.) — denying the agency’s motion for summary judgment and rejecting the adequacy of its search for records about the Rural Development Division’s rental assistance program; explaining that, while the agency’s supporting declaration “indicates that all the records in USDA possession have been produced, it contains no averments pertaining to the agency’s search” methodology, including descriptions of search terms and the types of searches actually performed.

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

Court opinions issued Mar. 11, 2025

Court Opinions (2025)Ryan MulveyComment

Ctr. to Advance Sec. in Am. v. USAID (D.D.C.) — granting the agency’s unopposed motion for a stay due to the “extremely limited” number of “USAID personnel available to work on Freedom of Information Act” matters—specifically, “three direct hire FOIA staff” and “nine institutional support contractors”; noting that USAID “cite[d] no authority in support of its request” for a stay, but understanding the request to arise under Open America; noting further that “the Court is skeptical that an agency can avoid its obligations under FOIA . . . by simply implementing a reduction-in-force . . . [or] more generally, by reducing the agency’s overall FOIA staff ‘by half,’” especially when there are no “external impediments to meeting the statutory requirements, such as a lack of funding from Congress or an unanticipated volume of requests that has overwhelmed the FOIA office”; warning that the stay is entered in large part because it is unopposed and “that this decision should not be understood to forecast how the Court is likely to resolve an opposed request for a stay under similar circumstances or a request by Plaintiff to lift the stay.”

Malik v. DHS (D.D.C.) — granting in part and denying in part the government’s motion for summary judgment, and denying the requester’s cross-motion; concluding, in large part, that the defendant-agencies conducted adequate searches for records concerning requester, notwithstanding the requester’s insistence they overlooked “materials which are known to exist”; upholding the agencies’ exemption claims based on the deliberative process, attorney-client, and attorney work-product privileges, as well as Exemptions 6, 7(C), and 7(E); yet also rejecting USCIS’s application of Exemption 7 to a “Memo for the Record” concerning the requester’s employment application because, as a “mixed-function agency,” the agency had failed to meet its burden to show how the record was “compiled for a law-enforcement purpose”; ordering USCIS to produce a supplemental affidavit addressing its law-enforcement functions vis-a-vis the contested memo or to proffer more detailed explanation for the applicability of Exemption 5.

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

Court opinions issued Mar. 10, 2025

Court Opinions (2025)Allan BlutsteinComment

Brennan Ctr. for Justice v. U.S. Dep’t of State (S.D.N.Y.) -- deciding that: (1) department performed a reasonable search for certain documents referenced in President Trump’s 2017 travel ban; and (2) following in camera review of four documents, all but three pages of one document were fully protected by the presidential communications privilege and Exemption 1.

Citizens for Responsibility & Ethics in Wash. v. U.S. DOGE Serv. (D.D.C.) -- in most notable part, granting plaintiff’s request for expedited processing of various records from the U.S. DOGE Service (USDS) because the “preliminary record” indicated that USDS “likely” wields substantial independent authority from the White House and therefore is any agency subject to FOIA.

Kendrick v. DEA (D.D.C.) -- on renewed summary judgment, determining that DEA performed adequate supplemental searches for records concerning pro se plaintiff’s criminal case.

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

Court opinions issued Mar. 6, 2025

Court Opinions (2025)Allan BlutsteinComment

Whitlock v. Dep’t of Def. (D.D.C.) — in case concerning federal corruption and bribery investigation involving the U.S. 7th Fleet, holding that: (1) government was entitled to summary judgment on issues uncontested by plaintiff, specifically that Navy conducted adequate searches and properly withheld records pursuant to Exemptions 5, 6, and 7(C); (2) government was required to release all records withheld pursuant to Exemption 7(A) because the criminal cases it identified as relevant were closed, and it failed to explain how disclosure of each category of withheld records would interfere with any Naval enforcement proceedings; and (3) government was required to release all records withheld pursuant to Exemption 7(B) because it failed to show that disclosure of each category of withheld records “would, more probably than not, seriously interfere with the fairness” of Naval enforcement proceedings.”

Gov’t Accountability Project v. Dep’t of the Treasury (D.D.C.) — finding that agency failed to show that Exemption 4 protected a company’s application and license to sell oil in Syria, because company’s unsworn statements made during the submitter notice process constituted inadmissible hearsay and, in any event, were too “vague and conclusory” to establish that the company customarily and actually treated the documents as private; further finding that some evidence supported Treasury’s position, including confidential markings on the disputed documents, and therefore denying both parties’ summary judgment motions.

Gatore v. Dep’t of Homeland Sec. (D.D.C.) — in dispute concerning a request for attorney’s fees, ruling that: (1) only one of dozens of plaintiffs established an attorney-client relationship with moving counsel; (2) plaintiff was eligible for attorney’s fees as a prevailing party because agency had been ordered to release certain documents, rejecting agency’s argument that plaintiff needed to prove she received documents from her counsel; and (3) whether plaintiff was entitled to fees under four-factor test was unnecessary to decide owing to her counsel’s “total lack of billing judgment in this case . . . despite repeated warnings from this Court and other members in this District regarding the serious deficiencies of his billing practices.”

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

Court opinion issued Mar. 3, 2025

Court Opinions (2025)Allan BlutsteinComment

Jensen v. SEC (D.D.C.) -- finding that SEC performed reasonable search for contract agreements and agency forms filed for two CUSIP numbers, which pro se plaintiff apparently hoped would “expose an alleged conspiracy, orchestrated by his sentencing court, to generate profit from the bonds associated with his criminal proceedings.”

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