Spadaro v. United States Customs and Border Protection, No. 19-1157 (2d Cir. 2020)
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The Second Circuit affirmed the district court's judgment in favor of the government defendants in a Freedom of Information Act (FOIA) action brought by plaintiff, seeking documents related to the revocation of his visa.
The court held that the contested documents were properly withheld under FOIA Exemption 3, and specifically INA 222(f), because they pertain to the issuance and refusal of a visa. Furthermore, officials properly invoked Exemption 3 to withhold revocation documents as they are related to visa issuances and refusals. Finally, plaintiff failed to meet his burden of demonstrating that the records are needed by a court "in the interest of the ends of justice," and the discretionary release of records under 8 U.S.C. 1202(f)(1) provides no basis for disclosure in this FOIA action. For the reasons set forth in a separate summary order addressing FOIA Exemption 5 filed simultaneously with this opinion, the court affirmed the judgment.
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