Stylianos v. USCIS, No. 20-11127, 2021 WL 294287 (D. Mass. Jan. 28, 2021) (Talwani, J.)

Stylianos v. USCIS, No. 20-11127, 2021 WL 294287 (D. Mass. Jan. 28, 2021) (Talwani, J.)

Re:  Request for one plaintiff's marriage certificate and Form I-130

Disposition:  Granting defendant's motion for summary judgment; denying plaintiffs' motion for summary judgment

Exemption 6:  The court finds that Exemption 6 applies to the requested documents.  First, the court finds that "this information [is] a 'record[ ] on an individual which can be identified as applying to that individual.'"  As to the public interest, the court finds that "Plaintiffs provide no argument as to how the requested documents may serve to open agency action to public scrutiny and the court finds none."  Regarding the privacy interest, the court finds that "even if [plaintiff's spouse's] marriage certificate may be obtained by petitioning the Cambodian government, it does not necessarily follow that [plaintiff's spouse] no longer has any expectation of privacy in the open dissemination of the document (even though it may, arguably, lessen her reasonable expectation of privacy)."