Hohman v. IRS, No. 18-1756, 2019 WL 1466980 (6th Cir. Apr. 1, 2019) (per curiam)

Hohman v. IRS, No. 18-1756, 2019 WL 1466980 (6th Cir. Apr. 1, 2019) (per curiam)

Re:  Request for records concerning third-party summonses to Chase Bank for financial records concerning requester

Disposition:  Affirming district court's grant of government's motion for summary judgment after adoption of magistrate judge's report and recommendation

• Litigation Considerations:  The Court of Appeals for the Sixth Circuit holds that "[the requester] provides no compelling reasons to ignore her waiver of the issues on appeal."  The court explains that "[p]arties waive their right to appellate review when they fail to object to the magistrate judge's report and recommendation."  The court finds that "[e]ven if [the requester] is correct that the district court erroneously balanced the privacy interests under 5 U.S.C. § 552(b)(7)(C), the only result is that she's denied access to the internal investigation files of two IRS employees who admitted they did not follow proper procedures in issuing third-party summonses."  "No one's constitutional rights are at stake . . . and an error here does not subject [the requester] to serious, life-altering consequences."  "It's just not the kind of error of considerable import that creates a manifest injustice if left uncorrected."