Wilson v. FBI (2nd Cir.) -- affirming district court’s decision denying plaintiff attorney’s fees after finding no “abuse of discretion” in lower court’s analysis of relevant “entitlement” factors; noting that although plaintiff was “eligible” for fees because district court had ordered FBI to conduct an additional search for records concerning plaintiff, FBI’s original decision not to search a particular database was reasonable given that no responsive records were located.
Schubert v. FBI (D.D.C.) -- (1) denying plaintiff’s motion to amend his complaint, because plaintiff impermissibly sought to expand the time scope of his request from nine months to 10 years; (2) FBI properly relied on Exemption 7(C) in refusing to confirm or deny records showing who accessed plaintiff’s criminal history; (3) FBI’s search for first-party records was not required by the request, but nevertheless finding that FBI’s voluntary search was adequate; and (4) Federal Bureau of Prisons performed adequate search despite also finding no records.
N.Y. Times v. FBI (S.D.N.Y.) -- following in camera review of report about “Havana Syndrome,” deciding that: (1) FBI properly redacted information concerning third parties pursuant to Exemption 7(C); and (2) FBI properly relied on Exemption 7(E) to redact certain portions of report, but it could not withhold the report in full using that exemption because one law enforcement technique was known to the public and the report’s introduction and conclusion did not reveal any techniques, procedures, or guidelines at all.
Summaries of all published opinions issued in 2024 are available here. Earlier opinions are available here.