Brick v. DOJ, No. 15-1246, 2017 WL 5198172 (D.D.C. Nov. 9, 2017) (Jackson, J.)

Brick v. DOJ, No. 15-1246, 2017 WL 5198172 (D.D.C. Nov. 9, 2017) (Jackson, J.)

Re:  Request for certain records concerning Eleanor Roosevelt

Disposition:  Denying defendant's motion for summary judgment; denying plaintiff's cross-motion for summary judgment

• Litigation Considerations, Vaughn Index/Declaration:  The court holds that "the proferred declarations do not provide a sufficient justification for these withholdings, because the declarations provide no details about, or context for, the FBI’s redaction determinations."  "The law is settled . . . that a declaration that does 'little more than parrot established legal standards' when explaining withholdings falls well short of meeting the government's obligations under the FOIA."  "[The] Court will provide the FBI with one additional opportunity to justify its withholdings fully; the agency must do so through submission of a supplemental declaration that addresses the concerns the Court has expressed in this Opinion and any others that the agency might identify as it undertakes to comply with the instant Order."  "The Court will also require the FBI to submit unredacted copies of the 12 disputed pages for in camera review."