National Whistleblower Center v. Department of Health and Human Services

How courts have described this case

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

• recognizing that Exemption 7 does not cover “personnel files maintained in the ordinary course of monitoring employees’ performance”
• holding that FOIA reques-ters lacked the injury in fact requirement of standing to challenge the agency’s dismissal of their administrative appeals when the agency no longer relied on its initially asserted FOIA exemptions
• concluding that handwritten-interview notes were part of the deliberative process where they “contain the author’s opinions, analysis, or impressions.” But notes that “merely record or summarize factual content from the meetings, calls, or interview . . . must be disclosed.”
• observing that records fell under Exemption 7(C) when they were “compiled to investigate allegations that [a] specific individual[ ] . . . had engaged in specific acts that could constitute violations of criminal and civil laws.”
• “The public no doubt has an interest in knowing whether [government agency] properly investigates allegations on misconduct...”
• “Handwritten notes may be deliberative or part of the agency’s deliberative process where they contain, the author’s opinions, analysis, or impressions of the event he or she describes”

Source: CourtListener parenthetical corpus (CC0).