Emanuel v. DOJ, No. 17-63, 2017 WL 4990518 (D.D.C. Oct. 30, 2017) (Howell, C. J.)

Emanuel v. DOJ, No. 17-63, 2017 WL 4990518 (D.D.C. Oct. 30, 2017) (Howell, C. J.)

Re:  Request for records concerning incident report involving plaintiff

Disposition:  Granting defendant's motion for summary judgment

• Exemption 7(C):  The court find that defendant's use of Exemption 7(C) was appropriate.  The court first finds that "[t]he requested records pertain to an incident report at a federal prison and thus satisfy the threshold law enforcement requirement of Exemption 7."  Next, the court finds that "BOP's declarant satisfactorily explains the harm in disclosing the third-party names[]" and "'[a]s a result of Exemption 7(C), . . . FOIA ordinarily does not require disclosure of law enforcement documents (or portions thereof) that contain private information,' . . . including the names of 'investigators, suspects, witnesses, . . . informants[.]'"  "[P]laintiff has not countered with a public interest to trigger the balancing requirement; therefore, the defendant, having properly justified the redactions, is entitled to judgment as a matter of law."