FOIA Advisor

Court opinion issued Apr. 10, 2026

Court Opinions (2026)Ryan MulveyComment

Informed Consent Action Network v. Food & Drug Admin. (D.D.C.) — granting the government’s motion for an Open America stay and staying litigation for “approximately seven months”; as with other recent cases, pointing to the government’s burdensome production schedule in a case in the Northern District of Texas, where the agency must “produce approximately 9.1 million pages by October 1, 2026”; denying the requester’s motion for discovery into the agency’s “multitrack process because such discovery would simply heighten the burdens on the agency, forcing [it] . . . to expend resources to reconstruct the statute of a queue from nearly three years ago,” and there is no evidence otherwise of bad faith.

Summaries of published opinions issued in 2026 are available here. Earlier opinions are available for 2025, 2024, and from 2015 to 2023.

FOIA News: FOIA Advisory Committee approves two recommendations

FOIA News (2026)Allan BlutsteinComment

By NARA/OGIS, FOIA Ombuds, Apr. 13, 2026

FOIA Advisory Committee Votes to Approve Two Recommendations

Members of the FOIA Advisory Committee voted to approve two recommendations at their April 2, 2026, meeting. The two recommendations came from the Statutory Reform Subcommittee and are: 

  • Recommendation No. 2026-01: Congress should amend FOIA to establish the FOIA Advisory Committee as a statutory federal advisory committee.

  • Recommendation No. 2026-02: Congress should amend FOIA to mandate regular publication of agency FOIA logs to contain, at a minimum, 13 fields generally maintained in agency FOIA tracking systems . . . .

Read more here.

[FOIA Advisor’s Ryan Mulvey co-chairs the subcommittee that initiated these recommendations]

Court opinion issued April 9, 2026

Court Opinions (2026)Allan BlutsteinComment

Coyne v. Nat'l Guard Bureau, Dep't of Def. (E.D. Pa.) -- denying cross-motions for summary judgment where pro se plaintiff sought Inspector General records related to his disputed retirement withdrawal; holding that the agency's declaration failed to establish the adequacy of its search in both completeness and method; holding further that the agency's Vaughn indices were insufficient for failing to describe withheld documents or explain the consequences of disclosure beyond rote recitation of claimed exemptions under Exemptions 5, 6, and 7(C); finding further that the agency's segregability showing was inadequate where the declaration offered only a blanket "inextricably intertwined" assertion without document-specific analysis; lastly, entering judgment for the agency on plaintiff's unpleaded Privacy Act claim.

Summaries of published opinions issued in 2026 are available here. Earlier opinions are available for 2025, 2024, and from 2015 to 2023.

Court opinions issued Apr. 7, 2026

Court Opinions (2026)Ryan MulveyComment

Hush Blackwell LLP v. Dep’t of Commerce (D.D.C.) — following supplemental briefing, granting the government’s renewed motion for summary judgment in a case involving access to final proposals to list foreign corporations on BIS’s export-restrictions list; holding, first, that the agency justified its invocation of Exemption 1 by identifying non-conclusory harms to national security that would result from disclosure, including the revelation of “sensitive collection capabilities and targets of foreign intelligence,” the “scope, methods, and strategic priorities of U.S. export control enforcements,” and other “strategic insights” into “national security decision-making processes”; holding, further, that the agency properly invoked Exemption 3, in conjunction with 50 U.S.C. § 4820(h)(1); reiterating the Court’s previously articulated view that, in light of the 2016 FOIA amendments, “segregation is not required for records properly withheld under exemption 3,” but in any event the agency demonstrated it undertook an adequate segregability review here; rejecting also the requester’s construction of the withholding provision at issue in the Export Control Reform Act of 2018.

Robert F. Kennedy Human Rights v. U.S. Dep't. of Homeland Sec. (S.D.N.Y.) — holding that partial government shutdown did not excuse DHS from complying with court-ordered FOIA production schedule; rejecting government's political question doctrine argument as "risible, if not sanctionable"; noting that DOJ's own contingency plan required agencies to continue court-ordered work during shutdowns as "excepted activity" under the Anti-Deficiency Act; and faulting government for unilaterally declaring a stay without seeking court relief.

Summaries of published opinions issued in 2026 are available here. Earlier opinions are available for 2025, 2024, and from 2015 to 2023.

Court opinion issued Apr. 3, 2026

Court Opinions (2026)Ryan MulveyComment

American Oversight v. Dep’t of Justice (D.D.C.) — in a case concerning access to “internal-training documents given to the DOJ personnel who reviewed and redacted the Epstein files,” denying the requester’s motion for a preliminary injunction ordering complete production before former Attorney General Bondi’s anticipated April 14, 2026 deposition before the House Oversight Committee; agreeing with the agency as to proper interpretation of the first factor of the relevant legal standard, namely, that the requester, “at a minimum, demonstrate its entitlement to expedited processing,” as set out in the FOIA statute; rejecting the requester’s alternative proposal that it only show entitlement to the records, as under this approach “a production injunction would be easier to obtain than an injunction for expedited processing,” which “make[s] little sense”; noting, further, that “no court in this district has ever granted a production preliminary injunction without first finding expedited processing warranted or noting that the Government had already agreed to expedite processing,” and neither has happened here; finally, with respect to irreparable harm, concluding that, while the “requested documents would be highly probative for . . . Bondi’s April 14 deposition,” “[t]here is no reason to think that the information Plaintiff seeks would become stale or irrelevant if produced” at a later date.

Summaries of published opinions issued in 2026 are available here. Earlier opinions are available for 2025, 2024, and from 2015 to 2023.

FOIA News: Yet another AI-powered request generator

FOIA News (2026)Allan BlutsteinComment

A new request platform called FOIAflow launched today, introducing an automated approach to submitting FOIA requests. Developed by high school student Amanuel Asfaw and his brother, the web application allows users to input an investigation topic, after which the system manages filing, follow-ups, appeals, and document analysis. The platform casts itself as a direct challenge to MuckRock: “MuckRock is a 15-year-old nonprofit running on donations. They help you file. FOIAflow fights for you autonomously, relentlessly, at a fraction of the cost per record.”

Monthly Roundup: March 2026

Monthly Roundup (2026)Allan BlutsteinComment

Below is a summary of the notable FOIA court decisions and news from last month, as well as a look ahead to FOIA events in April.

Court opinions

We identified 47 opinions in March, the largest number of opinions we have seen since March 2020 (52 opinions). Of note, in WP Co. LLC v. Nat’l Highway Traffic Safety Admin. (D.D.C. Mar. 25. 2026), which concerned records about crashes involving advanced driver-assistance systems, the court held that some data—like Tesla’s software-version and crash narrative information—could be withheld as confidential business information under Exemption 4, while other categories (including certain industry data and location details) required further scrutiny. Significantly, the court took a broad view of the foreseeable harm requirement in the Exemption 4 context, rejecting plaintiff’s argument that harm must come only from direct competitive use and recognizing reputational, inferential, and data-sharing harms.

Also of interest: Citizens for Responsibility & Ethics in Wash. v. CDC (D.D.C. Mr. 31, 2026 (allowing policy-or-practice claim to proceed against HHS for closing the CDC's entire FOIA office and rerouting all requests); and Heritage Found. v. DHS (D.D.C. Mar. 16, 2026) (rejecting government’s argument that plaintiff’s request involving more than 300,000 potentially responsive records was unreasonably described or unduly burdensome).

Top news

* Four cabinet departments, Agriculture, DHS, DOJ, and HHS, failed to post their annual FOIA reports in March. The government has not publicly explained the reasons for the delays.

* The Department of Veterans Affairs, which posted its annual report on March 27th, allowed its request backlog to balloon 130 percent from FY 2024 to FY 2025.

* The Office of National Cyber Security, a component of the Executive Office of the President, established in 2021, proposed its first-ever FOIA and Privacy Act regulations on March 31st.

April calendar

Apr. 2: FOIA Advisory Committee meeting

Apr. 8: DOJ/OIP training, Introduction to the Freedom of Information Act

Apr. 20-22: Graduate School USA training, Freedom of Information and Privacy Acts Course

Apr. 21: D.C. Circuit oral argument, Samara Simmons v. Dep’t of State, No. 25-5176

Apr. 22: DOJ/OIP training, Processing a Request from Start to Finish

Apr. 24: Deadline for agencies to submit FY26 data for quarter 2