FOIA Advisor

Court opinions issued Aug. 19, 2025

Court Opinions (2025)Allan BlutsteinComment

Grigsby v. DOJ (N.D. Cal.) -- ruling that FBI properly denied expedited processing of more than seven thousand responsive pages concerning plaintiff, finding that his age, past indictments (resulting in acquittals), and decades-old medica coverage did not establish a “compelling need.”

S. Envtl. Law Ctr. v. Tenn. Valley Auth. (E.D. Tenn.) -- concluding that: (1) TVA conducted reasonable searches for various records sought in three requests, including by consulting with subject-matter agency experts; (2) TVA properly relied on Exemption 4 to withhold contractor’s billing rates, pricing strategies, and other commercially valuable information; (3) TVA properly relied on the deliberative process privilege to withhold draft documents (with comments and track changes), communications reflecting recommendations, critiques, and give-and-take discussions; (4) TVA properly withheld certain records pursuant to the attorney work-product and attorney-client privileges; and (5) TVA met the foreseeable harm and segregability requirements for withholdings under both exemptions.

Baker v. FDA (E.D. Cal.) (Mag. J.) -- recommending dismissal of action for lack of jurisdiction because the requests at issue were submitted by plaintiff as president of his company, not by plaintiff individually, and therefore plaintiff lacked standing to sue; further finding that substituting the company as plaintiff would not cure the defect, because the company’s principal place of business was outside the district in which the case was filed.

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