Ezeah v. FBI (D.D.C.) -- granting government’s unopposed motion for summary judgment after concluding that: (1) FBI conducted an adequate search for records concerning plaintiff, a pro se prisoner; (2) FBI properly withheld records pursuant to Exemptions 5, 7(C), and 7(E), and met both the foreseeable harm and segregability requirements; and (3) FBI properly relied on Exemption 7(C) in refusing to confirm or deny existence of complaints filed against the FBI agent who interviewed plaintiff.
ACLU v. ICE (C.D. Cal.) -- granting in part and denying in part the parties’ cross-motions for summary judgment; finding that, despite the parties’ contentions, there were no genuine issues of material fact in dispute; concluding that, with respect to search adequacy vis-a-vis a portion of the request under litigation, ICE failed to provide an adequate justification for not following clear leads to further, “overlooked” responsive materials found in records produced to the plaintiff; concluding further that the agency improperly refused to conduct searches of other records locations and custodians which were reasonably held by plaintiff to contain responsive information; holding that the agency failed to properly follow-up with a component office that claimed it was unable to conduct a search in the first instance; noting, in that regard, that “as a policy matter, an agency cannot be said to have satisfied its burden under FOIA when a division within that agency, able to conduct a valid search, defers the search to another division, which is unable to conduct that search.”
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.