Louise Trauma Ctr. v. USCIS (4th Cir.) -- reversing district court’s decision and holding that: (1) plaintiff constructively exhausted its administrative remedies before filing suit for each of its requests, which USCIS acknowledged receiving but never otherwise responded to until litigation commenced; (2) agency’s post-litigation production of records did not moot plaintiff’s claims because agency did not produce all requested records and plaintiff disputed the withholdings; and (3) plaintiff was not required to file an administrative appeal to challenge agency’s post-lawsuit withholdings, noting that a contrary ruling would allow agencies “to engage in gamesmanship that would fundamentally undermine the FOIA timeliness requirement.”
Gilbert v. U.S. Air Force (D.D.C.) -- determining that: (1) the Air Force performed an adequate search for investigatory records concerning plaintiff, rejecting her contention of bad faith based on the delayed production of a key document; and (2) the Air Force properly relied on Exemption 3, in conjunction with the Inspector General Act of 1978, to withhold identifying information about a complainant, whose identity has not been made public through official disclosure.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.