ACLU of Northern California v. FBI, No. 16-15178 (9th Cir. 2018)
Annotate this CaseFor generalized records, such as training manuals and guidelines, the government's burden under Exemption 7 of the Freedom of Information Act (FOIA), 5 U.S.C. 552(b)(7), of demonstrating that withheld materials were "complied for law enforcement purposes" can be satisfied without linking the documents to the enforcement of a particular statute. The government need only show a "rational nexus" between enforcement of federal law and a withheld document to invoke Exemption 7. In this case, the Ninth Circuit vacated the district court's grant of summary judgment for plaintiffs in an action seeking information from the FBI under FOIA. The panel remanded for further proceedings.
Court Description: Freedom of Information Act The panel vacated the district court’s summary judgment that was entered in favor of the plaintiffs who had submitted Freedom of Information Act (“FOIA”) requests to the Federal Bureau of Investigation; and remanded for further proceedings. Exemption 7 of FOIA governs disclosure of records or information complied for law enforcement purposes. The panel held that for generalized records, such as training manuals and guidelines, the government’s burden under Exemption 7 of demonstrating that withheld materials were “complied for law enforcement purposes” can be satisfied without linking the documents to the enforcement of a particular statute. The panel further held that the agency need only establish a rational nexus between the withheld document and its authorized law enforcement activities. If such a showing is made, the district court can then determine whether disclosure would cause any of the specific harms
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