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American Immigration Lawyers Association v. Executive Office for Immigration Review

United States Court of Appeals for the District of Columbia Circuit
830 F.3d 667 (2016)


Facts

The American Immigration Lawyers Association (AILA) (plaintiff) filed a Freedom of Information Act (FOIA) request with the Department of Justice (DOJ) (defendant), seeking records of all complaints against the DOJ’s immigration judges. After six months of no response, AILA filed suit in federal district court seeking the information. Subsequently, the DOJ provided substantial complaint records but redacted the names of the immigration judges. Instead, the DOJ provided three-digit codes for each immigration judge to permit the tracking of judges subject to multiple complaints. In redacting the names, the DOJ invoked Exemption 6 under FOIA, which exempted from disclosure personnel files, “the disclosure of which would constitute a clearly unwarranted invasion of personal privacy.” The district court granted the DOJ summary judgment, finding that its redaction was valid. AILA appealed.

Rule of Law

Issue

Holding and Reasoning (Srinivasan, J.)

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