Duda v. DOJ (D.D.C.) -- in case concerning audio recordings related to FBI’s investigations of Emmett Till’s murder, ruling with respect to one recording that: (1) in camera review was needed to determine whether a source received an express or implied assurance of confidentiality, as the FBI claimed, because the court received a competing declaration from a former agency who originally obtained the recording; (2) FBI improperly relied on Exemptions 6 and 7(C) to withhold identifying details of third parties mentioned on the recording, noting that the agency had no basis to use the “100-year rule” to determine whether any person was still alive; further finding that there was a profound public interest in understanding the government’s handling of “one of the most consequential acts of racial violence in American history”; and (3) rejecting as “inconceivable” the FBI’s conclusory segregability claim that only one minute of the 100-minute recording could be released, emphasizing that targeted redactions or voice modulation could protect third party identities.
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