Rimmer v. Holder, No. 11-6286 (6th Cir. 2012)
Annotate this CaseIn 1998, Rimmer was convicted and sentenced to death for the murder of Ellsworth. Rimmer later learned that the federal government had conducted a joint investigation of Ellsworth’s murder with the Memphis Police Department, which, he claims, produced exculpatory evidence. Rimmer instituted state post-conviction proceedings, and obtained some, but not all, of the allegedly exculpatory evidence from the police department. Rimmer submitted a FOIA request that sought all relevant FBI documents. The FBI released 189 full or partially redacted pages from a total of 616 pages. The U.S. Department of Justice upheld the limited release. Rimmer filed claims under the APA, 5 U.S.C. 702, the Mandamus Act, 28 U.S.C. 1361, and FOIA, 5 U.S.C. 552(a)(4)(b). The FBI then determined that relevant files contained 786 pages and released them, but 704 pages were partially redacted. The district court dismissed Rimmer’s APA and mandamus claims as precluded by an adequate remedy under FOIA and granted the government summary judgment on Rimmer’s FOIA claim, holding that the redactions were proper under FOIA Exemptions 7(C) and 7(D) and that, in the case of the 7(C) redactions, there was not a “countervailing public benefit” to support disclosure of otherwise protected information. The Sixth Circuit affirmed.
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