Texas Pub. Policy Found. v. U.S. Dep’t of State (5th Cir.) -- reversing lower court in a 2-1 decision and holding that Exemption 6 did not protect the names and email addresses of rank-and-file State Department employees (i.e., non-policy makers) who were involved in developing President Biden’s emissions reduction target after rejoining the Paris Agreement; the majority found that the Department’s fears about potential harassment, doxing, or unwanted attention were not substantiated with credible evidence; that there was a significant public interest in understanding how government policy is formed, even when those involved are not senior officials; and that work-issued emails did not merit the same privacy protections as personal information; the dissent opined that Exemption 6 protected the names and email addresses of rank-and-file employees because their participation in “a high-profile and controversial matter” could expose them to harassment, whereas the rescinded nature of the emissions pledge weakened public interest in disclosure.
Citizens for Responsibility & Ethics in Wash. v. DHS (D.D.C.) -- ruling that DHS properly relied on Exemption 7(C) to withhold the identity of a Secret Service agent who had communicated with the founder of Oath Keepers concerning its potential presence at a September 2020 presidential rally; rejecting plaintiff’s argument that the communications at issue were created for political purposes rather than to fulfill the agency’s law enforcement mission; further, in weighing the agent’s privacy interests against any public interest in disclosure, the court rejected plaintiff’s argument that the agent acted improperly or that disclosure would shed additional light on Secret Service’s operations.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.