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Woods v. DOJ, No. 12-1701, 2013 WL 4852297 (D.D.C. Sept. 12, 2013) (Sullivan, J.)

Date: 
Thursday, September 12, 2013
Re: Request for certain records concerning plaintiff's criminal case Disposition: Granting defendant's motion for summary judgment
  • Litigation Considerations, Adequacy of the Search:  The court finds that it, "is satisfied from [defendant's] declaration that defendant's search was reasonably calculated to locate all responsive records."  The court rejects plaintiff's, "unsubstantiated 'belie[f] that there is more evidence or files within the Department of Justice's system of records that was 'withheld’ from [plaintiff's] trial attorney that could have exonerated the plaintiff during his jury trial.'"  The court finds that, "the FOIA request forming the basis of this action was addressed to [defendant], which is one of many [defendant] components, and 'the component that first receives a request for a record and has possession of that record is the component responsible for responding to the request.'"  Moreover, the court holds that, "an omitted record cannot alone support a finding of an inadequate search."
  • Exemption 7(C):  The court grants defendant's request for summary judgment on defendant's use of Exemption 7(C).  The court "is satisfied . . . that defendant released all reasonably segregable portions of information, and properly applied exemption 7(C) to the withheld third-party information."  Moreover, the court finds that, "[p]laintiff does not reasonably explain how releasing the withheld third-party information would shed any light on [defendant's] performance, and his personal stake in obtaining information in order to attack his conviction simply 'does not count in the calculation of the public interest.'"
Topic: 
Adequacy of Search
District Court
Exemption 7C
Litigation Considerations
Updated August 6, 2014