Grey v. Alfonso-Royals (4th Cir.) -- affirming district court's decision granting USCIS summary judgment and ruling that the agency properly redacted training materials under Exemption 7(E); notably, rejecting requester’s argument that Exemption 7(E) required a showing of risk of circumvention of the law for techniques or procedures, citing “basic rules of grammar and punctuation”; further, dismissing requester’s challenge to a provisional sealing and protective order, noting it was rendered moot by the district court's final ruling that authorized the redactions under FOIA.
Rudometkin v. United States (D.C. Cir.) -- reversing in part and granting in part district court’s decision concerning records related to requester’s military conviction, holding that: (1) U.S. Department of Defense properly relied on Exemption 5, rejecting requester’s argument that a “government misconduct” exception exists; (2) foreseeable harm was “manifest” due to the sensitive nature of disputed records, namely selecting a chief trial judge; (3) both the government and district court failed to adequately analyze whether non-exempt, reasonably segregable information could be released without causing harm; and (4) upholding the denial of requester’s motion to amend his complaint, because the FOIA claim he sought to add was being litigated in a separate, active case.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.