FOIA Advisor

Court opinions issued Mar. 23, 2022

Court Opinions (2015-2023)Allan BlutsteinComment

Cannady v. EOUSA (D.D.C.) -- holding that agency properly invoked Exemption 7(C) to withhold records concerning plaintiff’s criminal co-defendant, specifically inventories of items seized from co-defendant and notes of interviews between the FBI and co-defendant.

Gun Owners of Am. v. FBI (D.D.C.) -- ruling that: (1) FBI properly denied two requests as unreasonably described because plaintiff’s first request embedded “a fundamental uncertainty about whose communications [were] requested,” and its second request sought “all documents related to a certain question without providing further limitations or providing the FBI with a basis to narrow its search”; and (2) plaintiff’s remaining request was reasonably described “despite using the word ‘involving’ due to its inclusion of a discrete state agency whose communications are requested, specific search terms, explicit temporal parameters, and sufficient basis for the agency to narrow which custodians it must search to find responsive records.”

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