FOIA Advisor

Court opinion issued July 15, 2025

Court Opinions (2025)Ryan MulveyComment

Brown v. Fed. Bureau of Investigation (D.C. Cir.) — affirming the district court; holding that the FBI conducted an adequate search and properly interpreted a request for “witness accounts, narratives, or statements” to implicate, “in agency parlance,” only “formal witness interviews and memorialized FD-203 forms,” and not such materials as “records of 911 calls,” logs or recordings of “police radio communications,” or “raw recordings of witness interviews”; holding further that the FBI’s properly invoked Exemptions 6, 7(C), and 7(D); rejecting, specifically, the requester’s arguments that the agency had not satisfied the foreseeable-harm standard; finally, affirming the district court’s denial of in camera review.

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