Buzzfeed, Inc. v. Dep't of Ed., No. 18-01535, 2019 WL 3718928 (D.D.C. Aug. 7, 2019) (Cooper, J.)

Buzzfeed, Inc. v. Dep't of Ed., No. 18-01535, 2019 WL 3718928 (D.D.C. Aug. 7, 2019) (Cooper, J.)

Re:  Requests for records concerning resolution letters following investigation of whether covered school districts are adequately responding to sexual assault complaints by students sent to fourteen separate schools or districts

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

• Exemption 7(C):  The court notes that "[plaintiff] does not dispute that the records are tied to the Department's law enforcement efforts."  "After conducting an in camera review of each document and considering each redaction in light of the case law and the circumstances of each school or district, the Court concludes that while some of the redactions are appropriate, others are improperly broad."  "Many of the redactions protect traditional PII including dates or highly specific details that would allow identification of individuals involved in the underlying events that were investigated."  However, "[t]o the Court's eye, the redactions in these letters conceal significant amounts of information beyond the scope of either Exemptions 6 or 7(C)."  "These redactions hide details too general to allow for identification of individuals involved (particularly given the relatively large size of the districts), including information about the investigation that is not PII at all."  "If revealed, these details would illuminate [defendant's] work but would not risk identifying those involved in the underlying incidents."  "Further, because these redactions withhold substantial details about the [defendant's] Title IX investigations, they undermine 'the citizens' right to be informed about what "their government is up to,"' making the public interest in revealing much of the redacted information high."