FOIA Advisor

Court opinions issued July 13, 2020

Court Opinions (2015-2023)Allan BlutsteinComment

Talley v. DOL (W.D. Mo.) -- concluding that: (1) plaintiff’s claims were barred by res judicata because D.C. Circuit previously held that disputed records were properly withheld and plaintiff was serving as proxy for, and was in privity with, plaintiff in D.C. Circuit case; and (2) even if res judicata did not bar plaintiff’s claims, agency properly withheld records as privileged under Exemption 4.

Campo v. DOJ (W.D. Mo.) -- ruling that: (1) DOJ properly declined to search for third-party records in absence of subject’s written consent or proof of his death because records were protected by Exemptions 6 and 7(C), and plaintiff failed to demonstrate that public interest in disclosure outweighed subject’s privacy interests; (2) even if Exemptions 6 and 7(C) did not apply, requested records were protected as privileged under Exemption 4.

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