June 12, 2025
Huddleston v. FBI (E.D. Tex.) -- denying without prejudice plaintiff’s motion to substitute a third party to continue FOIA lawsuit because plaintiff did not mention third party by name or his purported interest in the requested information “throughout the over four years of litigation,” nor did plaintiff produce evidence that the third party had accepted the proposed substitution as party plaintiff.
June 11, 2025
Viola v. DOJ (D.D.C.) —determining that: (1) FBI performed adequate search for certain records concerning an FBI informant; (2) FBI properly relied on Exemption 7(C) to withhold identifying information about FBI’s special agents and professional staff, as well as other third party individuals; (3) information provided by FBI’s source was impliedly confidential and properly withheld under Exemption 7(D); (4) FBI properly withheld “non-public details about its storage device and identification number used to collect investigatory evidence” under Exemption 7(E); (5) FBI’s categorical withholding of an “informant file” consisting of evidentiary/investigative and administrative materials was proper under Exemption 7(D); and (6) FBI met FOIA’s foreseeable harm and segregability requirements.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.