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Citizens for Responsibility and Ethics in Washington v. Office of Administration

United State Court of Appeals for the District of Columbia Circuit
566 F.3d 219 (2009)


Facts

The Executive Office of the President of the United States (EOP) lost track of millions of White House e-mails. The Office of Administration (OA) (defendant) was a unit within the EOP. Citizens for Responsibility and Ethics in Washington (CREW) (plaintiff) submitted a request under the Freedom of Information Act (FOIA), 5 U.S.C. § 552, seeking OA records related to the missing e-mails. Despite initially agreeing to provide the requested information, OA later refused to produce the majority of its potentially responsive records. OA asserted that it was not an agency subject to FOIA, because OA’s sole function was to provide administrative support to the president and EOP staff. CREW filed a complaint against OA in federal district court. OA moved to dismiss the complaint. The district court granted OA’s motion, holding that OA was not an agency subject to FOIA’s disclosure requirements. CREW appealed.

Rule of Law

Issue

Holding and Reasoning (Griffith, J.)

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