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Allen v. BOP, No. 16-0708, 2021 WL 1124506 (D.D.C. Mar. 24, 2021) (Kollar Kotelly, J.)

Date

Allen v. BOP, No. 16-0708, 2021 WL 1124506 (D.D.C. Mar. 24, 2021) (Kollar Kotelly, J.)

Re:  Request for records concerning suspension of plaintiff's Trust Fund Limited Inmate Communication System privileges

Disposition:  Granting defendant's renewed motion for summary judgment

  • Exemption 7(C):  "[T]he Court identifies no public interest in disclosure of the USER IDs [of Bureau of Prisons ("BOP") staff members], and certainly no public interest sufficient to outweigh the privacy interest of BOP staff members."  The court relates that "BOP explains that each staff member is assigned 'a unique USER ID that allows [him or her] to log into BOP's network . . . .'"  "All USER IDs 'begin with the same letters but have unique numbers assigned.'"  "Each USER ID is unique to an individual . . . and contains 'personally identifiable information . . . tied to a specific staff member' . . . ."  "A staff member's duties determine which BOP databases he or she may access."  The court relates that "'BOP law enforcement officers perform constant monitoring of inmate emails and phone calls to determine if administrative discipline or referral for criminal prosecution is warranted.'"  "And if monitoring by BOP staff 'result[s] in administrative discipline or criminal prosecution, the targeted inmate may have hostility towards the staff member who monitored his emails.'"  "Disclosure, then, could subject these staff members 'to harassment, threats or violence both inside the prison and out in the community.'"  The court finds that "[i]t is plaintiff's obligation to articulate a public interest to outweigh the BOP staff members’ privacy interest, and the public interest must be significant."  "Plaintiff, who has not responded to BOP's sixth renewed summary judgment motion, fails to make such a showing."
     
  • Litigation Considerations, "Reasonably Segregable" Requirements:  "[T]he Court concludes that BOP has released all reasonably segregable information responsive to plaintiff's FOIA request."  The court relates that "BOP asserts that only the USER IDs appearing in the lower left corner of each page of email attachments are redacted."
Court Decision Topic(s)
District Court opinions
Exemption 7(C)
Litigation Considerations, “Reasonably Segregable” Requirements
Updated April 20, 2021