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Rodriguez v. FBI, No. 16-02465, 2020 WL 2559922 (D.D.C. May 20, 2020) (Mehta, J.)


Rodriguez v. FBI, No. 16-02465, 2020 WL 2559922 (D.D.C. May 20, 2020) (Mehta, J.)

Re:  Request for records concerning plaintiff's criminal case

Disposition:  Granting defendant's motion for summary judgment

  • Litigation Considerations, Adequacy of Search:  The court finds that "Defendant conducted an adequate search.  Defendant's declarant . . . sufficiently explains that 'no other record system was likely to produce responsive documents,' and 'show[s], with reasonable detail' that the agency's approach 'was reasonably calculated to uncover all relevant documents.'"  "He also disclosed 'the search terms and the type of search performed.'"
  • Litigation Considerations, Vaughn Index/Declaration:  The court holds that "[defendant's] Declaration 'contain[s] sufficient detail to allow a reviewing court to assess the applicability of the claimed exemptions to the undisclosed information.'"  The court relates that "[defendant] explains in detail why Defendant (and other agencies) withheld information on the basis of Exemptions 3, 5, 6, 7(A), 7(C), 7(D), 7(E), and 7(F)."  Additionally, the court finds that "[defendant's] categorical approach to describing these withholdings is appropriate."  "He defines the categories 'functionally,' establishes that he conducted a 'document-by-document review in order to assign documents to the proper category,' and explains how each category meets an exemption’s requirements."
  • Litigation Considerations, "Reasonably Segregable" Requirements:  The court finds that "[a] 'comprehensive Vaughn index, along with an affidavit [attesting] that a line-by-line segregability review [was conducted] of each document withheld in full,' is 'sufficient to fulfill the agency's obligation to show that further segregability was not feasible.'"  "Defendant has met that obligation."
Court Decision Topic(s)
District Court opinions
Litigation Considerations, Adequacy of Search
Litigation Considerations, Vaughn Index/Declarations
Litigation Considerations, “Reasonably Segregable” Requirements
Updated June 11, 2020