Albers v. FBI, No. 16-05249, 2017 WL 736042 (W.D. Wash. Feb. 24, 2017) (Settle, J.)
Date
Albers v. FBI, No. 16-05249, 2017 WL 736042 (W.D. Wash. Feb. 24, 2017) (Settle, J.)
Re: Request for records concerning plaintiff
Disposition: Granting defendant's motion for summary judgement
- Procedural Requirements, Searching for Responsive Records: The court holds that "[d]efendant FBI has met its burden to show beyond a material doubt that its records search was reasonably calculated to uncover all relevant documents." "Defendant FBI used the [Automated Case Support ("ACS")] case management system to conduct a main entries search of the Central Records System, which is where information about individuals, including Plaintiff . . ., is indexed." "Any records about Plaintiff . . ., if any, could be found with an ACS search." "The search was conducted with precision, with several search parameters, including date of birth, social security number, and multiple combinations of Plaintiff['s] . . . name." Responding to plaintiff's arguments, the court finds that: "all responsive records could be found using ACS, so a manual search was unnecessary[;]" "all records within the date range of the FOIA request were searchable using ACS[;]" and "[w]hile one interpretation of 'pertaining to' [in plaintiff's request] could include [plaintiff] as a primary subject or as an ancillary subject, it is not unreasonable to interpret 'pertaining to' in such a way as to search only for the primary subject of a particular matter[,]" and, therefore, a cross-reference records search was not required.
Court Decision Topic(s)
District Court opinions
Procedural Requirements, Searching for Responsive Records
Updated December 10, 2021