Stevens v. U.S. Dept. of State

Dist. Ct. did not err in granting defendant’s motion for summary judgment with respect to plaintiff’s three FOIA requests seeking materials relating to university campuses in foreign countries, as well as documents relating to U.S. Agency for International Development. During course of instant lawsuit, defendant produced some complete and partial records, as well as withheld some documents based on national security and deliberative-process exemptions. Moreover, defendant conducted additional searches based upon agreed-upon keywords to filter already-identified universe of potentially responsive documents. While plaintiff registered objection seven months after defendant had produced its key-word search, Dist. Ct. could properly find that said objection was untimely. Also, Ct. of Appeals rejected plaintiff’s claim that defendant made inadequate search for relevant documents, where: (1) agency’s sworn statements regarding its efforts to satisfy document requests enjoys presumption of good-faith; and (2) defendant provided documentation regarding its extensive, good-faith efforts to satisfy plaintiff’s three FOIA requests. Moreover, fact that plaintiff’ gave suggestion of locations that should have been searched did not require different result, where said locations either: (1) did not exist; (2) were in fact searched; or (3) were unlikely to have contained relevant documents. Too, defendant could properly withhold certain documents under national security exemption, where requests concerned confidential information regarding harassment of education official, as well as information revealed in confidence and information that risked harm to U.S.-Qatari relations.