On January 14, 2025, the United States Court of Appeals for the District of Columbia Circuit heard Brown v. FBI, No. 23-5244, which raised two issues regarding FBI’s investigation of the 2015 San Bernardino attack: (1) whether appellee properly construed the scope of appellant’s request under FOIA ; and (2) whether appellee satisfied its burden of demonstrating that disclosure of the material withheld under Exemption 7(D) would foreseeably harm an interest protected by that exemption.