Jensen v. SEC (D.D.C.) -- finding that SEC performed reasonable search for contract agreements and agency forms filed for two CUSIP numbers, which pro se plaintiff apparently hoped would “expose an alleged conspiracy, orchestrated by his sentencing court, to generate profit from the bonds associated with his criminal proceedings.”
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.
Feb. 28, 2025
United States v. Alexander (5th Cir.) (unpublished) -- vacating lower court’s decision denying plaintiff-appellee’s request for grand jury records pertaining to his criminal case, because FOIA does not apply to federal courts and therefore the district court lacked jurisdiction to entertain plaintiff’s FOIA claim.
Puzey v. DOJ (D.D.C.) -- in case concerning pro se inmate’s criminal case records, determining that: (1) DEA, FBI, EOUSA, and ATF performed adequate searches, an issue plaintiff did not dispute; (2) plaintiff did not meaningfully dispute EOUSA’s withholdings under Exemptions 3 and 5; (3) FBI and EOUSA properly withheld the names of agency employees, third parties, and state and law enforcement pursuant to Exemptions 6 and 7(C); (4) government properly withheld records pursuant to Exemptions 7(D), 7(E), and 7(F), rejecting plaintiff’s public interest arguments as irrelevant; and (5) plaintiff conceded government’s foreseeable harm and segregability requirements.
Biggins v. USPS (D.N.J.) (unpublished) -- dismissing claim because plaintiff failed to send his request to a designated request center, he failed to label his request per agency regulations, and he improperly asked for information instead of records.
Feb. 27, 2025
Louise Trauma Ctr. v. ICE (D.D.C.) -- concluding that ICE did not sufficiently explain its search methodology for requested training material; that in camera review of agency’s Exemption 5 redactions was warranted; and that plaintiff’s request concerning agency’s information processing system was not reasonably described.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.
February 26, 2025
Leopold v. Dep’t of State (D.D.C.) — deciding that: (1) agency improperly relied on the deliberative process privilege’s consultant corollary doctrine to withhold its communications with pending nominees to Senate-confirmed positions, because a nominee has a self-interested, independent stake in the confirmation process; (2) agency properly withheld talking points and many other—but not all— records under the deliberative process privilege; and (3) agency met the foreseeable harm and segregability requirements.
February 25, 2025
Transgender Law Ctr. v. ICE (D.D.C.) — in case concerning agency’s treatment of transgender detainees, concluding that: (1) ICE’s search was deficient because the agency neglected to clearly show that it searched the email accounts of two relevant employees, it unreasonably omitted one search term, and it unreasonably used another search term only in combination with other words; and (2) ICE failed to properly support its withholdings under Exemption 5’s attorney-client and deliberative process privileges, including whether foreseeable harm would result from disclosure; (3) ICE did not show how the records withheld under Exemptions 7(C) and 7(E) met the law enforcement threshold; (4) ICE improperly relied on Exemption 6 to withhold agency email domain addresses, to categorically withhold the names of “lower-level” agency employees and third parties, and to withhold name of a training video narrator.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.
Turse v. DOD (D.D.C.) — in a case concerning records about a US drone strike in Somalia, granting the agency’s motion for summary judgment and concluding that its withholding of a PowerPoint slide and Army Regulation 15-6 Report of Investigation under Exemption 1 was appropriate; noting the agency’s declaration adequately described why the records at issue were classified and how disclosure would harm national security; rejecting the requester’s contention that the records were classified “for a prohibited purpose” for lack of evidence; similarly rejecting the requester’s arguments that the agency failed to satisfy the FOIA’s foreseeable-harm standard.
Dawkins v. FBI (E.D.N.Y.) — deciding that FBI performed an adequate search for any surveillance records about pro se plaintiff and his residence; plaintiff was not entitled to in camera review of documents because FBI’s declaration sufficiently detailed its search methodology and explained why it withheld certain records; plaintiff’s request for a court order ending FBI’s alleged surveillance could not be considered because plaintiff failed to raise those allegations in his complaint.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.
Hvistendahi v. DOJ (S.D.N.Y.) -- in case concerning an Office of Inspector General’s report about personal misconduct of FBI employees overseas, concluding that: (1) FBI established that dates and locations of the misconduct, as well as the direct quotations from OIG interviews, implicated personal privacy interests under Exemption 7(C), but those interests were outweighed by a “significant public interest” in disclosure; and (2) FBI properly relied on Exemption 7(C) to withhold the “unsubstantiated allegations against FBI officials and the reasons why OIG found them unsubstantiated.”
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.
Am. Oversight v. DOJ (D.D.C.) — denying plaintiff’s request expedited processing in a case concerning access to volume two of former Special Counsel Jack Smith’s report on the possession of classified documents at Mar-a-Lago; holding that the motion for preliminary injunctive relief did not establish how the relief sought (specifically, disclosure of the report before any Senate confirmation vote on Kash Patel) would alleviate any ostensibly irreparable harm, in large part because another court has already enjoined DOJ from releasing the report “no matter what exemption decisions it makes”; questioning also whether the requester’s motion even seeks the type of injunctive relief permitted in the FOIA context.
The Brady Ctr. to Prevent Gun Violence v. FBI (D.D.C.) — determining that the FBI failed to show that disclosure of an agency’s standard operating procedures for the National Instant Criminal Background Check System would enable individuals to circumvent the law for purposes of Exemption 7(E); reserving judgment on the FBI’s segregability analysis until after the agency renewed its summary judgment motion or altered its withholdings; granting summary judgment to the FBI on non-contested information withheld under Exemption 5 and Exemption 7(E).
Magassa v. TSA (D.D.C.) — ruling that: (1) TSA properly relied on Exemption 3 in conjunction with 49 U.S.C. § 114(r) to withhold records concerning the plaintiff, a former employee of Delta Airlines whose security credentials were revoked; (2) TSA properly invoked Exemption 3 in refusing to confirm or deny the existence of records indicating whether plaintiff is on a federal watch list; and (3) TSA substantiated its Exemption 5’s attorney-client and attorney work-product privilege redactions for records generated during the course of administrative proceedings concerning the plaintiff’s revoked security credentials.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.
Feds for Freedom v. DOD (D.D.C.) — granting the agency’s motion for summary judgment and concluding that “it need not response to the request because its scope is so unreasonably expansive that processing and responding to it would be unduly burdensome”; taking note of an agency declaration that stated complying with the request would implicate “over 1.2 gigabytes of records,” including “over 2,000 emails, each with attachments,” totaling more than “26,000 pages”; noting further these records would require “the most scrutinous review,” or “about 6,500 hours of work.”; finally, concluding “that the breadth of Plaintiff’s request is unreasonable in light of Plaintiff’s asserted purpose” for seeking records, namely, to “protect employee rights by confronting the federal government’s mandates requiring vaccination for COVID-19.”
Wilson v. FBI (D.D.C.) — granting the agency’s motion for summary judgment and holding its “search was sufficient” and “invocation of FOIA exemptions . . . proper”; rejecting the requester’s argument that the agency improperly refused to employ desired search terms and to search in the FBI’s Electronic Surveillance and DELTA databases; with respect to Exemption 7(C), holding that the agency correctly withheld the names and identifying information of government investigators and third parties; with respect to Exemption 7(E), accepting the withholding of “an internal email address, non-public intranet addresses, and non-public phone numbers”; finally, holding that the agency’s use of Glomar was proper with respect to (1) national security and intelligence-related records protected by Exemptions 1 and 3, as well as records identifying individuals (2) in the witness security program, (3) on a watchlist, or (4) who are confidential sources.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.
Am. Immigration Council v. EOIR (D.D.C.) — granting in part and denying in part the parties’ cross-motions for summary judgment, and ordering the agency to undertake a supplemental search; concluding that EOIR “properly understood the scope of Plaintiffs’ FOIA request” to seek “official” documents about immigration court practices, but the agency nevertheless inappropriately limited its search to “solely centrally disseminated records” and improperly excluded records created locally by individual immigration courts and judges; concluding further that certain aspects of EOIR’s search were inadequate.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.
Heritage Found. v. CIA (D.D.C.) — granting the CIA’s motion for judgment on the pleadings with respect to the plaintiff’s expedition request because that request lacked the required certification that the grounds for seeking expedition were “true and correct,” which thus rendered it deficient; rejecting the plaintiff’s arguments that its non-compliance should be excused because “this is not a case where . . . [it] ‘matters’” and it subsequently added the necessary “magic words” in a second request for expedition; noting that the ruling does not impact the requester’s remaining claims and does not foreclose a motion for leave to amend or supplement the Complaint.
S. Envtl. Law Ctr. v. Tenn. Valley Auth. (E.D. Tenn.) — denying the government’s partial motion to dismiss for lack of subject-matter jurisdiction, where the requester attempted to challenge the agency’s search adequacy after filing suit for lack of a timely response; holding that the FOIA’s right to judicial review does not distinguish between “an agency’s compliance with the timeframe clause . . . [and] the disclosure, reasonable search, and/or exemption subparagraph(s)”; noting that “Defendant’s labyrinthine conception of the FOIA seems contradictory to the very purposes for which Congress enacted” the law, and if “the Court [were] to take this argument to its logical conclusion, agencies could short-circuit judicial review through precisely the procedural dynamics of this case: force a requester to seek judicial review by failing to timely respond, disclose some requested material only after a suit is filed, and immediately move to dismiss any potential challenge to the adequacy of the disclosure, itself, on grounds of subject matter jurisdiction.”
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.
Leopold v. FBI. (D.D.C.) — in a case concerning access to the FBI’s Mar-a-Lago investigative file, rejecting the agency’s reliance on Exemption 7(A) and its Glomar response, in large part because there is no longer any pending law enforcement proceeding (i.e., charges against President Trump have been dismissed), and future proceedings are not reasonably anticipated as President Trump is likely immune from prosecution; noting further that the agency failed to support its position with any suggestion of alleged criminal conduct by President Trump after the 2020 presidential election.
Summaries of all published opinions issued in 2025 are available here. Earlier opinions are available for 2024 and from 2015 to 2023.