FOIA Advisor

Court opinion issued Aug. 18, 2025

Court Opinions (2025)Allan BlutsteinComment

Lenz v. CIA (D D.C.) -- on renewed summary judgment concerning the 1962 Stonehill raids in the Philippines, holding that: (1) the CIA properly withheld records concerning “a range of [CIA] functions and operations” pursuant to Exemption 1, finding its updated Vaughn Index and partial document releases sufficient, and concluding that classification was not invalidated by potentially illegal government conduct ; (2) the CIA properly relied on Exemption 3 in conjunction with 26 U.S.C. § 6103 to withhold third-party tax-identifying information, rejecting plaintiff’s unsupported claim that the information was already public; and (3) at the FBI’s request, the properly withheld the names and identifying information of “third parties of investigative interest” under Exemption 7(C) and foreign government agency information under Exemption 7(D), dismissing plaintiff’s speculation that a redacted name was a deceased person with no privacy interests.

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