Below is a summary of the notable FOIA court decisions and news from last month, as well as a look ahead to FOIA events in July.
Court decisions
We identified and posted 16 opinions in June—twice as many as in May. Two cases are worth revisiting. In FOIAConsciousness.com v. NARA (N.D. Cal., June 30, 2025), which involved a request for a copy of the Zapruder film, the court blessed NARA’s three-part access scheme: (1) providing viewing access in Maryland and allowing copies to be made for requester’s own use; (2) allowing requester to hire an individual to visit Maryland to make self-serve copies; and (3) allowing requesters to order copies through selected vendors, but requiring permission from any copyright holders that may exist. The court reasoned that vendor-facilitated copies were not “readily reproducible” in the absence of a copyright holder’s permission. The second notable case is S. Envtl. Law Ctr. v. Tenn. Valley Auth. (E.D. Tenn.), which curiously relied on a non-FOIA case in deciding that plaintiff lacked standing to pursue a FOIA claim on the grounds that it failed to present sufficient evidence of its purported informational injury.
Although excluded from our opinions list, we note that the U.S. Supreme Court issued a two-page order on June 6th that limited discovery in a FOIA case against DOGE.
Top news
Amtrak became the first agency to propose amendments to their FOIA regulations since President Trump took office on January 20, 2025.
The federal FOIA Advisory Committee met on June 12, 2025, and it is now less than one year away from completing its term on June 11, 2026.
Bill Moyers, an influential journalist and early FOIA supporter, died at age 91.
July events
July 4: FOIA signed by President Lyndon Johnson in 1966, effective one year later.
July 10: DOJ/OIP. Privacy Consideration Training.
July 15: DOJ/OIP. Continuing Freedom of Information Act Education Training.
July 23: OGIS annual public meeting
July 25: Agency FY25 Q3 Data Due.
July 28-30: Management Concepts, The Privacy Act and The Freedom of Information Act Training.
July 30: Catholic Legal Immigration Network, Navigating FOIA and Records Requests.