Cochran v. DHS, No. 18-201, 2019 WL 1433014 (D. Md. Mar. 28, 2019) (Hollander, J.)

Date: 
Thursday, March 28, 2019

Cochran v. DHS, No. 18-201, 2019 WL 1433014 (D. Md. Mar. 28, 2019) (Hollander, J.)

Re:  Request for "'all documents pertaining to [plaintiff's] security clearance'"

Disposition:  Granting defendant's motion for summary judgment

  • Litigation Considerations, Adequacy of Search:  The court holds that "[t]he exhibits describe the searches, identify search terms, the specific locations that were searched, and indicate that all files likely to contain responsive materials were searched."  The court also finds that "[plaintiff] provided no support for her assertion that FEMA 'must' have the document in its possession."  "'A mere deductive inference that a record "must" exist, without proof, does not raise a material issue of fact regarding the adequacy of an agency's search.'
Topic: 
Adequacy of Search
District Court
Litigation Considerations
Updated April 11, 2019