Court Decisions

Karam v. Meta Platforms, Inc., No. 25-01397, 2025 WL 3079048 (N.D. Cal. Nov. 4, 2025) (Martínez-Olguín, J.)

Re: Request for records concerning “‘unauthorized surveillance and data collection activities conducted by Meta Platforms, Inc. in cooperation with government agencies’”

Disposition:  Granting defendant’s motion to dismiss FOIA claim

• Procedural Requirements, Entities Subject to the FOIA:  The...

Viola v. DOJ, No. 18-2573, 22-2186, 2025 WL 3059805 (3d Cir. Nov 3, 2025) (Phipps J.)

Re: Requests for records concerning the requester

Disposition:  Affirming in part and vacating in part district court’s grant of government’s motion for summary judgment

• Procedural Requirements, Entities Subject to the FOIA:  “[Plaintiff] contends that the Task Force is a federal agency because it receives federal...

Stevens v. Dep’t of the Army, No. 25-5144, 2025 WL 3072660 (N.D. Ill. Nov. 3, 2025) (Kennelly, J.)

Re: Requests for records concerning Northwestern University’s expansion of its campus into Lake Michigan around 1960s

Disposition:  Denying defendant’s motion for summary judgment; granting in part and denying in part plaintiff’s cross-motion for summary judgment

• Litigation Considerations, Exhaustion of...

Noh v. United States, No. 25-01483, 2025 WL 3062714 (W.D. Wash. Nov. 3, 2025) (King, J.)

Re: Request for certain surveillance records

Disposition:  Denying plaintiff’s motion for reconsideration and dismissing plaintiff’s complaint

• Litigation Considerations, Pleadings:  The court finds that “[i]f [plaintiff] intended to bring a standalone claim under the [FOIA], she has not stated a claim under that...

Williams & Connolly, LLP v. DHS, No. 24-2322, 2025 WL 3039859 (D.D.C. Oct. 31, 2025) (Friedman, J.)

Re: Request for records concerning individual that plaintiff alleges testified at trial in exchange for immigration benefits

Disposition:  Granting defendants’ cross-motion for summary judgment; denying plaintiff’s motion for partial summary judgment

• Litigation Considerations, Evidentiary Showing...

Levigne v. Sides, No. 25-1816, 2025 WL 3055178 (W.D. Wash. Oct. 31, 2025) (Evanson, J.)

Re: Issue surrounding incident involving plaintiff

Disposition:  Dismissing plaintiff’s FOIA claim

• Litigation Considerations, Pleadings:  The court finds that “while the complaint contains a single reference to FOIA, it alleges no facts supporting a FOIA claim or indicating that Plaintiff has met FOIA’s...

Conte v. FBI, No. 23-3729, 2025 WL 3037877 (D.D.C. Oct. 30, 2025) (Kelly, J.)

Re: Request for records concerning alleged FBI confidential human source

Disposition:  Granting defendant’s motion for summary judgment; denying plaintiff’s motion for summary judgment

• Litigation Considerations, Evidentiary Showing, Declarations & In Camera Inspection: The court finds that, “[f]or the reasons explained in...

Ecological Rts. Found. v. U.S. Army Corps of Eng’rs, No. 23-05309, 2025 WL 3022853 (N.D. Cal. Oct. 29, 2025) (Chesney, J.)

Re:  Request for records concerning certain dams and hydropower facilities

Disposition:  Granting in part and denying in part plaintiff’s motion for attorney fees and costs; awarding plaintiff $145,863.70 in attorney fees and $792.46 in costs

• Litigation Considerations, Exhaustion...

New Orleans Navy Hous., LLC v. U.S. Dep’t of Navy, No. 25-363, 2025 WL 2997382 (E.D. La. Oct. 24, 2025) (Africk, J.)

Re: Request for records concerning Military Housing Privatization Initiative

Disposition:  Granting defendant’s motion for summary judgment

• Exemption 5, Deliberative Process Privilege & Attorney-Client Privilege:  “[T]he Court holds that the Navy has met its burden of demonstrating...

Levitt v. IRS, No. 25-949, 2025 WL 2987881 (N.D. Ala. Oct. 23, 2025) (Carney Axon, J.)

Re: Request for tax records concerning his client

Disposition:  Dismissing action without prejudice

• Litigation Considerations, Standing:  The court relates that “[plaintiff] is an attorney, and he represents Potts Mountain Reserve IP, LLC.”  “[Plaintiff] filed a FOIA request with the IRS on behalf of Potts Mountain...