Amiri v. Nat'l Sci. Found., No. 21-5241, 2022 WL 1279740 (D.C. Cir. Apr. 28, 2022) (per curiam)

Amiri v. Nat'l Sci. Found., No. 21-5241, 2022 WL 1279740 (D.C. Cir. Apr. 28, 2022) (per curiam)

Re:  Request for records concerning requester and one of National Science Foundation's grant awards

Disposition: Granting government's motion for summary affirmance

• Litigation Considerations, Considerations on Appeal:  The Court of Appeals for the District of Columbia Circuit noted that "[t]he district court concluded that [the government] conducted an adequate search . . . , properly applied FOIA Exemptions 5 and 6 to withhold certain information, and released all reasonably segregable, non-exempt information."  "[The requester] does not present any substantive arguments challenging the district court's conclusions and has therefore forfeited them."
   
• Procedural Requirements, Searching for Responsive Records:  The Court of Appeals for the District of Columbia Circuit found that the requester's "suggestion that the National Science Foundation Office of Inspector General should have responded to his request lacks merit."  The government "did not send his January 2020 FOIA request to the Office of Inspector General, which handles FOIA requests separately . . . and [the government] had no obligation 'to look beyond the four corners of the request.'"
   
• Waiver and Discretionary Disclosure:  The requester "asserts that the documents at issue 'were already public knowledge and could not be sealed.'"  "But [the requester] has not demonstrated that [the government] waived its right to invoke an applicable FOIA Exemption by inadvertently producing unredacted documents . . . nor has he shown that the documents were otherwise publicly available."