Greenspan v. DOT (D.D.C.) -- ruling that: (1) the National Highway Traffic Safety Administration properly withheld Tesla-related documents under Exemption 4 and that disclosure would cause foreseeable competitive harm to Tesla and undermine NHTSA’s ability to gather similar data; rejecting plaintiff’s argument that NHTSA’s delay in ruling on Tesla’s confidentiality requests meant the information should no longer be protected under FOIA; and (2) NHTSA properly relied on Exemption 5’s deliberative process privilege to withhold to internal discussions on whether and how to investigate Tesla, and that disclosure would foreseeably harm agency decision-making by discouraging candid internal dialogue.
Zaid v. DHS (D. Md.) -- determining that: (1) ICE performed a reasonable search and properly withheld records under Exemption 7(A) due to their connection to active child exploitation investigations; and (2) ICE properly withheld identifying information about third parties under Exemptions 6 and 7(C), rejecting plaintiff’s argument that names of all ICE employees at GS-14 salary level or above must be disclosed.
New Orleans Navy Hous. v. U.S. Dep't of Navy (E.D. La.) -- in a case concerning records related to the management and funding of a military housing project, finding that the Navy properly withheld some records pursuant to Exemption 5’s deliberative process privilege, but held that its foreseeable harm explanations and many of its Vaughn Index entries were insufficient; the court also rejected plaintiffs’ argument that the withheld documents related solely to contract administration and were therefore categorically outside the scope of the privilege.
Nat’l Pub. Radio v. U.S. Cen. Command (S.D. Cal.) -- in ongoing case concerning a friendly fire incident in Afghanistan, tentatively ruling that plaintiff was both eligible and entitled to interim attorney’s fees and costs; further, tentatively deferring its decision as to the hours, costs and final amount appropriate and ordering parties to attend a settlement conference with magistrate judge.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.
