Samann v. Commissioner

How courts have described this case

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

• holding that emails that document ongoing internal debates and contain back-and-forth and the exchange of ideas are pre- decisional and deliberative
• holding that the agency must demonstrate why disclosure of the withheld material “in the specific context of the agency action at issue, actually impede[s] those same agency deliberations going forward”
• holding that the Federal Bureau of Investigations (FBI) through “a series of boilerplate and generic assertions” failed to demonstrate a foreseeable chilling effect on internal communications as a result of public release
• holding that “a ‘perfunctory state[ment] that disclosure of all the withheld information . . . would jeopardize the free exchange of information between senior leaders within and outside the [agency]’ will not suffice”
• explaining that “the basis and likelihood of [the claimed] harm must be independently demonstrated for each category” (citation omitted)
• reaffirming that redactions in Machado Amadis were properly justified because “the government directly articulated a link between the specified harm and the specific information contained in the material withheld” (cleaned up)

Source: CourtListener parenthetical corpus (CC0).