Pronin v. BOP, No. 17-1807, 2020 WL 1189386 (D.D.C. Mar. 12, 2020) (Kelly, J.)
Date
Pronin v. BOP, No. 17-1807, 2020 WL 1189386 (D.D.C. Mar. 12, 2020) (Kelly, J.)
Re: Request for records concerning plaintiff and certain BOP facilities
Disposition: Granting defendant's renewed motion for summary judgment
- Litigation Considerations, Adequacy of Search: The court holds that "it was reasonable for BOP – in response to [plaintiff's] FOIA requests for staff lists at three of its facilities – to search those facilities' personnel databases in the ways described." The court finds that "BOP's declaration . . . details the methods, databases, and records that Human Resources Division staff searched at each BOP facility."
- Exemption 6: The court holds that "BOP properly relied on Exemption 6 to withhold the requested information." The court finds that "[BOP staff lists at three facilities where plaintiff was incarcerated] are 'personnel' files or similar '[g]overnment records on an individual which can be identified as applying to that individual.'" The court then finds that "there is no cognizable public interest at stake." "The disclosure of BOP staff names and positions 'sheds no light on the activities of the BOP.'" "And the 'public has no cognizable interest in the release' of names and titles that 'reveal[ ] little or nothing about an agency's own conduct' . . . ." "[Plaintiff's] personal interest in discerning potential defendants for his own litigation 'does not count in the calculation of the public interest.'" "The Court need not decide precisely how great BOP's staff's privacy interests are in this regard." "Suffice it to say that BOP's declaration establishes that they have some privacy interest in their names and positions, one that is 'greater than [ ] de minimis' for purposes of Exemption 6 . . . ."
Court Decision Topic(s)
District Court opinions
Exemption 6
Litigation Considerations, Adequacy of Search
Updated April 15, 2020