Friday, April 13, 2018
Jackson v. GSA, No. 17-2847, 2018 WL 1779333 (3d Cir. Apr. 13, 2018) (per curiam)
Re: Request for records concerning requester
Disposition: Affirming district court's grant of government's motion for summary judgment
- Litigation Considerations, Adequacy of Search: "[The Court of Appeals for the Third Circuit] agree[s] that the defendants' submissions in this case establish that the search was adequate and 'reasonably calculated to uncover all relevant documents.'" The court finds that defendant's "declarations described [the] request, identified the employees who were involved in the search, explained the search terms used, specified the systems that were searched, and stated that all files likely to contain responsive materials had been searched." "The IRS and GSA employees also submitted amended and supplemental declarations in response to specific complaints raised by [the requester] in response to the motion for summary judgment." Responding to plaintiff's argument, the court finds that "[the requester's] 'mere speculation that as yet uncovered documents might exist, does not undermine the determination that the agency conducted an adequate search for the requested records.'"
Adequacy of Search
Court of Appeals
Updated July 2, 2018