Prison Legal News v. Samuels, No. 13-5269, 2015 WL 3513372 (D.C. Cir. June 5, 2015) (Randolph, S. J.)

Prison Legal News v. Samuels, No. 13-5269, 2015 WL 3513372 (D.C. Cir. June 5, 2015) (Randolph, S. J.)

Re: Request for records concerning money BOP paid in connection with lawsuits and claims brought against it between January 1, 1996 and July 31, 2003

Disposition: Reversing and remanding district court's grant of defendant's motion for summary judgment

• Litigation Considerations, Vaughn Index/Declaration; Exemption 6:  "[The Court of Appeals for the District of Columbia Circuit] decline[s] to engage in the required balancing in the first instance and therefore will remand the case to the district court."  The court finds that "it is difficult to see how the categories in [defendant's] Declaration support application of exemption 6."  "The categories, centered as they are on specific types of filed documents, include a wide range of claims covering various degrees of privacy interests."  Specifically, the court finds that "[t]he district court failed to give any weight to the distinction between the accused and the accuser when balancing private and public interests."  "In addition, the Bureau has not been consistent in shielding the names of its employees accused of wrongdoing."  The court finds that "the privacy interests involved in a given type of claim do not fall within a single category that 'characteristically support[s] an inference that the statutory requirements for exemption are satisfied.'"  The court holds that "[t]he public interest in disclosure will vary based on the individual's role in a given claim—victim, perpetrator, witness, medical professional diagnosing an inmate, and so forth—and the nature of the claim itself."  "These differences in interest do not warrant the categorical approach taken in [defendant's] Declaration and . . . Vaughn Index."  The court holds that, "[o]n remand, the Bureau must fashion a coherent catalogue of the documents still in dispute and the district court must balance the privacy and public interests in light of the Bureau's new submissions."