Freedom Watch, Inc. v. Dep't of State, No. 14-1832, 2016 WL 1555672 (D.D.C. Apr. 15, 2016) (Boasberg, J.)

Date: 
Friday, April 15, 2016

Freedom Watch, Inc. v. Dep't of State, No. 14-1832, 2016 WL 1555672 (D.D.C. Apr. 15, 2016) (Boasberg, J.)

Re: Request for records concerning sanctions waiver State Department granted certain countries doing business with Iran

Disposition: Granting defendant's renewed motion for summary judgment

  • Procedural Requirements, Searching for Responsive Records:  "[T]he Court will grant Defendant's Motion for Summary Judgment."  Despite plaintiff's arguments, the court explains that "because the case was remanded with instructions about searching only Secretary Clinton's emails . . . [plaintiff] cannot complain that Defendant should have examined other records systems for responsive material."  "The only live question, therefore, relates to the manner in which the emails were searched."  On that issue, the court finds that the "method of search appears entirely reasonable to the Court" and that "[t]his is particularly so because Plaintiff does not challenge either the search terms themselves or the date range employed."  Instead, the court relates that "[p]laintiff's central argument does not take issue with the mechanics of the search; [plaintiff], instead, maintains that State's search must be deficient simply because it uncovered no responsive documents."  However, the court finds that "[p]laintiff . . . relies on . . . mislabeled press releases and news articles as the basis for its . . . argument."  For that same reason, "the Court may easily deny" "that discovery is necessary here."  Overall, the court finds that "[p]laintiff's Opposition [to defendant's renewed motion for summary judgment] may be characterized by Yogi Berra's immortal line, 'It’s déjà vu all over again.'"  "This is because it essentially reiterates the arguments that the Court previously found wanting."
Topic: 
District Court
Procedural
Search
Updated June 2, 2016