Doe v. FEC, No. 17-2694, 2018 WL 1461964 (D.D.C. Mar. 23, 2018) (Jackson, J.)
Re: Plaintiffs' challenge to decision to disclose their identities when FEC publicly releases file pertaining to an investigation that is now closed
Disposition: Not enjoining defendant's disclosure of plaintiffs' identities pursuant to the agency's disclosure policy
- Exemption 7(C): The court holds that "[p]laintiffs also rely on FOIA principles when identifying the privacy interests the agency was bound to protect." "They point out that FOIA Exemption 7(C) exempts from disclosure information compiled for law enforcement purposes, which 'could reasonably be expected to constitute an unwarranted invasion of personal privacy[.]'" "But John Doe 2 is a trust . . . and under well-established FOIA principles, an entity has no right to 'personal privacy' under FOIA Exemption 7(C)." "And the actions of John Doe 1, as the trustee for John Doe 2, were solely on behalf of the trust, not himself, so his asserted privacy interests are minimal."