Center for Constitutional Rights v. Central Intelligence Agency
United States Court of Appeals for the Second Circuit
765 F.3d 161 (2014)
- Written by Eric Miller, JD
Facts
Mohammed al-Qahtani, a Saudi national, was a high-profile detainee at Guantanamo Bay, where he was held on suspicion of involvement in the attacks of September 11, 2001. In 2010, the Center for Constitutional Rights (CCR) (plaintiff) requested videos and photographs of al-Qahtani pursuant to the Freedom of Information Act (FOIA). In 2012, having received no response from the United States government (defendant), the CCR brought suit in federal district court. In response, the government identified 62 records of al-Qahtani but claimed the right to withhold them under FOIA Exemption 1, which authorized the nondisclosure of records for purposes of national security. The government argued that images involving al-Qahtani, if made public, could be used by terrorist groups for anti-American propaganda purposes, potentially endangering United States military personnel in Afghanistan and elsewhere. The CCR argued that the propaganda justification was overly broad. The court found in favor of the government. The CCR appealed to the United States Court of Appeals for the Second Circuit.
Rule of Law
Issue
Holding and Reasoning (Cabranes, J.)
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