Stevens v. HHS (N.D. Ill.) -- on renewed summary judgment, holding that: (1) government was not required to file a motion under Rule 60(b) seeking relief from court’s prior summary judgment ruling because the court had not entered final judgment; (2)(a) the Executive Office for Immigration Review’s supplemental search for emails about third parties was inadequate because the agency failed to explain why it did not use the subjects’ A-numbers as search terms; and (b) EOIR unreasonably limited its search to a five-year period where plaintiff asked for decade’s worth of records and the agency’s record retention period is seven years; (3) EOIR was not required to release deduplicated records, rejecting plaintiff’s argument that deduplication is a per se FOIA violation; (4) EOIR was not required to produce an “irreparably damaged” audio recording that could not be copied; (5) EOIR’s referral of emails to DHS was not improper; and (6) EOIR’s “short description” of its withholdings under Exemption 5’s deliberative process privilege were insufficient to carry agency’s burden.

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