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Bolin v. NARA, No. 25-00043, 2025 U.S. Dist. LEXIS 164286 (D. Nev. Aug. 22, 2025) (Baldwin, Mag. J.)

Date

Bolin v. NARA, No. 25-00043, 2025 U.S. Dist. LEXIS 164286 (D. Nev. Aug. 22, 2025) (Baldwin, Mag. J.)

Re:  Request for declaratory judgment that NARA violated FOIA by failing to proactively disclose records related to assassination of President John F. Kennedy

Disposition:  Dismissing case as moot

  • Litigation Considerations, Mootness and Other Grounds for Dismissal:  The court relates that “shortly after the filing of this lawsuit, President Trump issued Executive Order 14,176, which required the declassification of the JFK Collection in its entirety.”  “[Plaintiff] acknowledges that this lawsuit is now ‘practically moot’ because of the entry of Executive Order 14,176, which has resulted in the full release and digitization of the JFK Collection.”  “Despite acknowledging this fact, Plaintiff requests that the Court enter summary judgment in his favor by granting him declaratory relief indicating NARA’s ‘pre-Executive Order conduct violated FOIA’s mandate that agencies proactively disclos[e] “frequently requested” records under 5 U.S.C. § 552(a)(2)(D).’” “The Court finds that this case is now moot based on Executive Order 14,176, which both parties concede in their respective filings.” “The Court therefore does not consider the merits-based arguments for and against summary judgment raised in the parties[’] motions.”  “Based on the undisputed evidence presented to the Court, the entire JFK Collection is now publicly available and digitized.”  “Accordingly, the controversy at issue in [plaintiff’s] complaint has now terminated and there is no present controversy for which this Court can grant any relief.”
Court Decision Topic(s)
District Court opinions
Litigation Considerations, Mootness and Other Grounds for Dismissal
Updated September 12, 2025