Alfredo Rosillo v. Matt Holten

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• determining that the court need not resolve the appropriateness of an agency’s Glomar response after the agency withdrew its Glomar response and searched for responsive 27 records
• explaining that distribution is determinative in cases where it “serve[s] as evidence that” the records “‘were created for the purpose of conducting agency business’” (quoting Bureau of Nat’l Affairs, 742 F.2d at 1496 (emphasis omitted)
• finding that “in light of the overlap between [two] subcomponents” of a plaintiff’s FOIA request, “there is no reason to believe that the [agency’s] overall search for responsive material would not have identified any material responsive to [both] subcomponent[s]”
• rejecting the agency's Exemption 5 argument for withholding a memorandum describing the agency's decision making process without making recommendations
• rejecting the agency’s Exemption 5 argument for withholding a memorandum describing the agency’s decision making process without making recommendations
• noting “documents can be ‘agency records’ under FOIA even if they need not have been preserved (or created) under federal law or agency practice”

Source: CourtListener parenthetical corpus (CC0).