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Hall v. Stoneman, No. 19-109, 2020 WL 1451586 (D.D.C. Mar. 25, 2020) (Walton, J.)


Hall v. Stoneman, No. 19-109, 2020 WL 1451586 (D.D.C. Mar. 25, 2020) (Walton, J.)

Re:  Request for return of plaintiff's "'supporting documents' that he allegedly submitted to the DOJ to investigate alleged violations of his civil rights"

Disposition:  Granting defendants' motion for summary judgment

  • Litigation Considerations, Mootness and Other Grounds for Dismissal:  "[T]he Court finds that no triable issue exists concerning the DOJ's responses to the plaintiff's FOIA request and that the DOJ is entitled to summary judgment."  "First, [responding to plaintiff's argument, the court finds that] the fact that the released records were not the original documents is irrelevant."  "An agency's FOIA obligations extend only to records that it possesses and controls at the time of the FOIA request."  "The FOIA therefore provides for the release of copies as substitutes for originals, and courts have long anticipated this alternative."  "As for the delayed release of records, the plaintiff merely posits that it 'was done intentionally to help discredit the issues raised in [his] complaint [ ] to the agency' about his conviction."  The court finds that "[s]uch speculation is wholly inadequate to create a triable issue of fact under the FOIA."  "It is the law in this circuit that 'however fitful or delayed the release of information under the FOIA may be, once all requested records are surrendered, federal courts have no further statutory function to perform.'"
  • Exemption 7(C):  The court holds that "although the plaintiff has not disputed the government's minimal redaction of 'the victim's name' from the released grand jury transcript, . . . the Court notes that '[s]uch information is ‘"categorically" protected from disclosure under exemption 7(C) absent the plaintiff's showing that "a significant public interest exists for disclosure."'"
Court Decision Topic(s)
District Court opinions
Exemption 7(C)
Litigation Considerations, Mootness and Other Grounds for Dismissal
Updated May 1, 2020