Karl Gallant v. National Labor Relations Board

How courts have described this case

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

• concluding that a Vaughn index was not required for a determination of whether the requested documents were “agency records” subject to FOIA
• concluding that an agency official’s personal letters were not agency records based on, inter alia, “other employees’ lack of reliance on the correspondence to carry 21 out the business of the agency”
• holding that letters sought in a FOIA request were personal rather than \agency records\ because they were created for a \purely personal objective\ and neither the author nor other employees \reli[ed] on the correspondence to carry out the business of the agency\
• holding that letters sought in a FOIA request were personal rather than “agency records” because they were created for a “purely personal objective” and neither the author nor other employees “reli[ed] on the correspondence to carry out the business of the agency”
• noting that summary judgment is not appropriate where the agency affidavits contain “merely conclusory statements”
• deciding a case primarily based on “[t]he actual use of the correspondence, … and other employees’ lack of reliance on the correspondence to carry out the business of the agency”

Source: CourtListener parenthetical corpus (CC0).