FOIA Advisor

Court opinion issued June 10, 2022

Court Opinions (2015-2023)Allan BlutsteinComment

Avila v. U.S. Dep't of State (D.D.C.) -- holding that: (1) agency’s use of plaintiff’s full name as sole search term was too narrow to uncover all records responsive to plaintiff’s request for records concerning a February 2011 attack involving plaintiff; (2) agency adequately justified withholding some but not all documents pursuant to Exemption 1, and it provided inadequate description for one document withheld under Exemption 3 in conjunction with the National Security Act; (3) agency properly relied on Exemption 5’s deliberative process privilege to withhold draft documents, all but one document constituting outward-facing deliberations, and all but two miscellaneous records; and (4) agency properly withheld emails reflecting policy and legal advice pursuant to the attorney-client privilege.

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