Aguiar v. EOUSA, No. 20-5245, 2021 U.S. App. LEXIS 10354 (D.C. Cir. Apr. 9, 2021) (per curiam)

Aguiar v. EOUSA, No. 20-5245, 2021 U.S. App. LEXIS 10354 (D.C. Cir. Apr. 9, 2021) (per curiam)

Re:  Requests for records concerning investigation of requester

Disposition:  Granting government's motion for summary affirmance

• Attorney Fees:  The Court of Appeals for the District of Columbia Circuit holds that "[t]he district court's conclusion that appellant had not demonstrated that he obtained relief with respect to his Freedom of Information Act requests through 'a voluntary or unilateral change in position by the agency,' . . . was not clearly erroneous."  "'[T]he mere filing of the complaint and the subsequent release of the documents is insufficient to establish causation.'"