The New York Times Co. v. U.S. Department of Health and Human Services, No. 21-211 (2d Cir. 2021)Annotate this Case
The Second Circuit held that a report evaluating the Indian Health Service's management and administration is not a "medical quality assurance record" under 25 U.S.C. 1675, and thus not exempt from disclosure under the Freedom of Information Act (FOIA). This case arose from plaintiffs' request of a report from Indian Health Services under FOIA, and the Department's subsequent denial of the FOIA request pursuant to section 1675. The court found the Department's remaining arguments to be without merit and affirmed the district court's grant of summary judgment to plaintiffs.