FOIA Advisor

Court opinion issued August 1, 2025

Court Opinions (2025)Ryan MulveyComment

Leopold v. U.S. Secret Serv. (D.D.C.) — in a case over “documents concerning any Presidential records that were removed from the White House to Mar-a-Lago,” holding that the requester was “eligible for and entitled to a fee award,” but limiting the award to “20% of the amount claimed,” or $15,955; rejecting the government’s argument that to qualify as “eligible” for a fee award on a catalyst theory the requester must actually obtain records; on the question of entitlement, finding there was some public benefit derived from the suit, even though no further records were located or released, given the public interest in the underlying subject matter; at the same time, concluding “[t]here was a reasonable basis for Defendants’ refusal to search,” but this “is insufficiently decisive to counterbalanace” the other factors weighing in the requester’s favor; ultimately reducing the attorneys’ fee request by 80%.

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