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Jackson v. EOUSA, No. 17-02208, 2019 WL 1046295 (D.D.C. Mar. 5, 2019) (McFadden, J.)


Jackson v. EOUSA, No. 17-02208, 2019 WL 1046295 (D.D.C. Mar. 5, 2019) (McFadden, J.)

Re:  Request for records concerning plaintiff's criminal case

Disposition:  Granting defendant's motion for summary judgment

  • Procedural Requirements, Searching for Responsive Records:  The court finds that "[defendant] located files associated with [plaintiff's] criminal case and a related civil case."  "[Defendant] then searched these files for records about a search warrant for the UPS package [plaintiff] identified in his FOIA request."  "This was a reasonable and logical process to look for any relevant documents."  Responding to plaintiff's argument, the court finds that "'[m]ere speculation that as yet uncovered documents may exist does not undermine the finding that the agency conducted a reasonable search for them.'"
  • Exemption 6:  "The Court finds that EOUSA properly applied Exemption 6."  First, the court finds that certain information "qualifies as 'similar files' under Exemption 6."  Next, "the Court finds that the third parties whose information EOUSA redacted have a substantial interest in protecting their privacy."  The court also finds that "[plaintiff] identifies no public interest, compelling or otherwise, why such third-party information should be disclosed."
  • Litigation Considerations, "Reasonably Segregable" Requirements:  The court holds that "EOUSA's declarant identifies the particular information withheld on each of the 10 pages of records at issue and explains why EOUSA made these limited redactions."  "The Court finds that the declaration adequately establishes that EOUSA has released all reasonably segregable information."
Court Decision Topic(s)
District Court opinions
Exemption 6
Litigation Considerations, “Reasonably Segregable” Requirements
Procedural Requirements, Searching for Responsive Records
Updated January 11, 2022