Zhao v. Dep't of State, No. 18-2541, 2019 WL 4267854 (2d Cir. Sept. 10, 2019) (per curiam)

Zhao v. Dep't of State, No. 18-2541, 2019 WL 4267854 (2d Cir. Sept. 10, 2019) (per curiam)

Re:  Request for records concerning Iraq War that requester allegedly submitted to United States embassy in Thailand

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

• Procedural Requirements, Searching for Responsive Records:  The Court of Appeals for the Second Circuit holds that "[t]he government's search terms were reasonable."  The court finds that "[i]n [its] declaration, [the government] describes with reasonable specificity the search the government conducted, including the search terms it employed."  "In particular, the government searched for variations and iterations of [the requester's] name; 'Bangkok,' where [the requester] states he delivered [certain] materials; [the name of] the United States Ambassador to Thailand at the time [the requester] delivered the materials; and 'Iraq War.'"  "[The requester] argues that the government should have used the search terms 'Saddam Hussein' as well as 'any of the key words used in the slogan by the United States in the Iraq War.'"  "But [the requester] requested documents 'regarding the Iraq war'; his FOIA request did not mention Saddam Hussein."