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Judicial Watch v. Dep't of Treasury, No. 15-1776, 2017 WL 1207414 (D.D.C. Mar. 31, 2017) (Collyer, J.)

Date

Judicial Watch v. Dep't of Treasury, No. 15-1776, 2017 WL 1207414 (D.D.C. Mar. 31, 2017) (Collyer, J.)

Re: Request for records concerning former Secretary of State's use of private email server in emails at other federal agencies

 

Disposition: Granting defendant's motion for summary judgment

  • Procedural Requirements, Searching for Responsive Records: The court holds that "the operative question is not whether a global search of all employees is technically possible, but whether Treasury's searches were 'reasonably calculated to uncover all relevant documents.'" The court finds that "[w]hile it may be the case that Treasury could perform a global search of all its employees' emails, there is no indication that such a search of non-senior employees would be reasonably calculated to uncover relevant documents." "There is further no allegation or indication that Treasury undertook its searches in bad faith." "Treasury identified the relevant records to search and searched them using appropriate search terms." "FOIA requires no more."
Court Decision Topic(s)
District Court opinions
Procedural Requirements, Searching for Responsive Records
Updated December 15, 2021