FOIA Advisor

Court opinions issued Sept. 10-11, 2019

Court Opinions (2019)Allan BlutsteinComment

Sept. 11, 2019

Barry v. Koskinen (D. N.J.) -- determining that plaintiff failed to administratively appeal from IRS denial of his request for oaths, qualifications, and bonds of certain agency employees.

Sept. 10, 2019

Wen Dong Zhao v. U.S. Dep't of State (2nd Cir.) -- summary order affirming district court’s decision that agency performed reasonable search for research documents that plaintiff allegedly provided to the United States Embassy in Bangkok, Thailand in 2003.

Long v. CIA (D.D.C.) -- of note, holding that CIA had not demonstrated that writing new computer code to locate responsive records in its FOIA database or compiling resulting records would constitute creation of new records or be “extremely burdensome.”

Summaries of all published opinions issued since April 2015 are available here.