Borowski v. U.S. Customs & Border Prot. (W.D.N.Y.) -- finding that: (1) agency failed to adequately explain its search methodology in response to request for records concerning plaintiff; and (2) agency’s Vaughn Index lacked sufficient detail to allow court to evaluate withholdings under Exemptions 6, 7(C), and 7(E); and (3) agency’s withholding claim under Exemption 5’s deliberative process privilege also lacked a sufficient basis, nor did agency meet its foreseeable harm burden.

Summaries of all published opinions issued in 2024 are available here. Earlier opinions are available here.