People for the Ethical Treatment of Animals v. National Institutes of Health, Department of Health & Human Services

How courts have described this case

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

• holding that, in issuing a Glomar response, an agency “need not conduct any search for responsive documents or perform any analysis to identify segregable portions of such documents.”
• holding that a Glomar response was unwarranted for a request seeking documents showing that, in response to complaints filed against three named individuals, the agency conducted an investigation that did not target those (continued on next page
• explaining that when there is “a category of responsive documents for which a Glomar response would be unwarranted, [an agency’s] assertion of a blanket Glomar response to [that part of the] request cannot be sustained”
• placing particular weight on an agency’s official acknowledgment that it had conducted an investigation into an individual
• permitting blanket Glomar response “as to any documents that would confirm the existence of an investigation into the three named researchers”
• confining its FOIA analysis to Exemption 7(C) because its “privacy language is broader than the comparable language in Exemption 6” (quoting Reporters Comm., 489 U.S. at 756, 109 S.Ct. 1468)

Source: CourtListener parenthetical corpus (CC0).