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Bell v. ATF, No. 17-1221, 2020 WL 42840 (D.D.C. Jan. 3, 2020) (Kelly, J.)


Bell v. ATF, No. 17-1221, 2020 WL 42840 (D.D.C. Jan. 3, 2020) (Kelly, J.)

Re:  Request for records concerning murders of four individuals

Disposition:  Granting defendant's motion for summary judgment

  • Litigation Considerations, Adequacy of Search:  "In light of ATF's supplemental searches, which did yield additional responsive documents, and its description of the types of searches performed and the search terms used, the Court agrees that ATF has 'conducted a search of records systems reasonably likely to contain responsive information using search methods that were reasonably designed to locate such information.'"  "In its prior order, the Court stated that it could not determine whether ATF's search had been adequate due to the relative paucity of information about how the search and subsequent review of documents had been conducted."  "ATF has now cured this deficiency."
  • Exemptions 6 & 7(C):  "[T]he Court finds that the redacted portions of the responsive documents were properly withheld pursuant to FOIA Exemption 7(C)."  The court finds that "ATF represents that the information redacted is, in summary, identifying information (including names, birthdays, addresses, and phone numbers) of suspects, criminal associates, witnesses, Baltimore Police Department detectives, and ATF agents."  "Release of this information could subject these individuals to danger or harassment, and there is little countervailing public interest."  Additionally, the court explains that "[b]ecause records properly withheld under Exemption 7(C) are also properly withheld under Exemption 6, the Court need not conduct a separate Exemption 6 analysis."
Court Decision Topic(s)
Exemption 6
Exemption 7(C)
District Court opinions
Litigation Considerations, Adequacy of Search
Updated March 3, 2020