Monday, March 11, 2019
Cochran v. DHS, No. 18-202, 2019 WL 1129437 (D. Md. Mar. 11, 2019) (Hollander, J.)
Re: Request for plaintiff's Family & Medical Leave Act records from 1962 to present
Disposition: Granting defendant's motion for summary judgment
- Litigation Considerations, Adequacy of Search: The court holds that "[plaintiff's] Declaration, coupled with the FEMA exhibits, establish FEMA's compliance with the FOIA in regard to the adequacy of the search itself." "The 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."
- Attorney Fees, Eligibility: "To the extent plaintiff requests fees and costs associated with filing this action, [the court] shall deny such a request." The court finds that "plaintiff has failed to show that she has 'substantially prevailed' on her FOIA claim."
Adequacy of Search
Updated March 29, 2019