FOIA Advisor

Court opinion issued Dec. 20, 2023

Court Opinions (2015-2023)Allan BlutsteinComment

Muzumala v. FBI (S.D.N.Y.) -- finding that: (1) FBI timely responded to plaintiff’s request by regular mail to plaintiff’s last known address, rejecting plaintiff’s argument that he was entitled to a response via email; (2) FBI performed a reasonable search for records concerning plaintiff, who provided no evidence that agency had responsive records; and (3) U.S. Immigration and Customs Enforcement performed adequate search for records concerning plaintiff and properly withheld certain records pursuant to Exemption 3 in conjunction with 49 U.S.C. § 114(r), as well as Exemptions 6, 7(C), and 7(E).

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