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Ludlam v. U.S. Peace Corps., No. 11-1570, 2013 WL 5273918 (D.D.C. Sept. 19, 2013) (Sullivan, J.)

Re: Requests for results of surveys of Peace Corps volunteers for specified years
Disposition: Denying plaintiff's motion for reconsideration
  • Exemption 6:  The court concludes that program-by-program survey results were properly withheld pursuant to Exemption 6.  "If breakdown of survey results at the country-by-country level presents a substantial likelihood that concrete facts about a particular individual could be inferred, as the Court previously found, it follows that the breakdown at the program-by-program level within a particular country presents even more risk of invading personal privacy."  Noting that plaintiff has reasserted the same arguments regarding an alleged public interest, the court declines to grant the motion for reconsideration.  Additionally, the court remarks that "[c]ontrary to plaintiff's claims, the Court did not rely on the Volunteer Protection Act or declare that the Volunteer Protection Act and FOIA must be construed in tandem in making the determination of proper withholding under Exemption 6."  "The Court only considered the Volunteer Protection Act in response to plaintiff's reference to the Act to support his claim that there is congressional and public interest in information regarding the Peace Corps staff performance, at a country-by-country level, in protecting the safety of Volunteers serving in different host countries."  "[T]he court noted the "lack of support" for "the claim that there is public interest in the program-by-program survey results."  Accordingly, the court rules that the privacy interest identified by defendant justified withholding the program-by-program survey results.  Noting that "plaintiff does not claim that the Court misunderstood the parties, made a decision beyond the issues presented, failed to consider controlling decisions, or that there was a significant change in the law or the facts," the court denies the motion for reconsideration.
Court Decision Topic(s)
District Court opinions
Exemption 6
Updated August 6, 2014