Zaldivar v. Dep't of Veterans Affairs, No. 16-16580, 2017 WL 3499802 (9th Cir. Aug. 16, 2017) (per curiam)

Zaldivar v. Dep't of Veterans Affairs, No. 16-16580, 2017 WL 3499802 (9th Cir. Aug. 16, 2017) (per curiam)

Re:  Request for records concerning requester's veterans benefits

Disposition:  Affirming district court's grant of government's motion for summary judgment

• Litigation Considerations, Adequacy of Search & Exemption 6:  The Court of Appeals for the Ninth Circuit holds that "[t]he district court properly granted summary judgment on [the requester's] claims related to his . . . FOIA . . . requests because [the requester] failed to raise a genuine dispute of material fact as to whether appellee had not conducted a reasonable search for responsive documents or whether appellee did not establish the redactions on the documents were exempt from disclosure under FOIA[.]"  The district court previously held that "[the government] [has] met [its] burden of showing that [it] conducted a search for documents that was 'reasonably calculated to uncover all relevant documents' by [describing] where [it] conducted the search and the methods [it] used" and "[the requester] has not identified what public interest would be served by the disclosure of [a third party's] contact information and social security number."
   
• Litigation Considerations, Statute of Limitations:  The Court of Appeals for the Ninth Circuit holds that "[t]he district court properly dismissed as time-barred [the requester's] claims related to his October 20, 2002, April 13, 2005, and July 10, 2007 FOIA . . . requests."