Milliron v. DOD (W.D. Mich.) -- adopting magistrate judge’s report and recommendation and holding that the department properly withheld portions of a Georgia Tech report under Exemption 4; rejecting plaintiff’s claim that the report was intended for public release, finding instead that it was clearly labeled as confidential, designated for internal government use only, and contained proprietary methodologies protected from disclosure.
Aland v. U.S. Dep’t of the Interior (N.D. Ill.) -- dismissing plaintiff’s claims against the U.S. Fish & Wildlife Service and the Office of the Secretary, because plaintiff appealed the FSW’s denial after the 90-day deadline and his appeal to the Secretary failed to include certain documents required by Departmental regulations.
Lowe v. U.S. Dep't of Justice Office of Info. Policy (S.D.N.Y.) -- adopting magistrate judge’s report and recommendation and finding that: (1) EOUSA conducted an adequate search for records concerning plaintiff’s criminal case and properly withheld records pursuant to Exemptions 3, 5, 6, 7(C), 7(D), 7(E), and 7(F); and (2) neither EOUSA nor DEA was required to re-process a DEA interview report that EOUSA located only in redacted form, but plaintiff could submit a separate request to DEA directly.
Informed Consent Action Network v. NASA (D.D.C.) -- in case concerning communications between two Caltech-employed scientists at NASA’s Jet Propulsion Laboratory, ruling that the records weren’t “agency records” because they were created and stored by Caltech employees and NASA did not control the records as they were on Caltech systems, not government servers.
Khatchadourian v. FBI (D.D.C.) -- granting partial summary to both parties in case concerning records about James Ralph Rose, Jr., who was convicted in 1979 for plotting to bomb whaling vessels in Chile; specifically, the court held that: (1) the FBI failed to justify its use of Exemption 7(C) to withhold names of deceased individuals, those who signed waivers, or whose identities were already public; (2) the FBI met its burden to protect the identity of confidential informants under Exemption 7(D); (3) the FBI’s explanations were too vague and conclusory to justify its Exemption 7(E) withholdings; (4) the FBI could not rely on Exemption 7(F) to withhold explosives-related information already made public at trial, or to withhold the name of law enforcement personnel because the supporting affidavit was unsigned; and (5) the FBI’s Glomar responses, to which plaintiff did not dispute, were upheld under Exemptions 1, 3, 7(D), 7(E), and 7(F).
Eban v. DOD (D.D.C.) -- in case concerning “Operation Whitecoat”—a Cold War-era U.S. Army medical research program that used volunteer Seventh-Day Adventist soldiers as test subjects in biological warfare experiments—the court found that: (1) the Army failed to conduct an adequate search for electronic records at two key research facilities due to incomplete search terms, a limited search scope, and inconsistencies in the Army’s declarations; emphasizing that searching only the "most likely" location for responsive records was insufficient and that the Army was required to search all locations reasonably likely to contain responsive records; and (2) the Army’s search for physical records at various facilities was sufficient, reasoning there was no strong evidence that responsive records existed only in hard-copy form and had not been accounted for through electronic searches.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.