Buckley v. DOJ (2nd Cir.) (unpublished) — affirming district court’s decision that: (1) the FBI properly relied on Exemptions 7(D) and 7(E) to withhold records concerning their domestic terrorism investigation of plaintiff-appellant, which concluded without charges, and (2) plaintiff-appellant was ineligible for attorneys’ fees. The Court rejected the argument that Exemption 7 was inapplicable because the records were allegedly compiled for “political reasons,” explaining that circuit precedent requires courts to presume that all investigatory records from law enforcement agencies are compiled for a law enforcement purpose. On fees, the court held that plaintiff-appellant failed to show he was a prevailing party under the catalyst theory. Notably, he failed to raise an argument in district court that earlier-submitted release forms supported his catalyst claim, thus precluding the Court from considering it on appeal.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.