National Day Laborer Organizing Network v. United States Immigration and Customs Enforcement Agency
United States District Court for the Southern District of New York
877 F. Supp. 2d 87 (2012)
The National Day Laborer Organizing Network (organization) (plaintiff) filed a 21-page Freedom of Information Act (FOIA) request for electronically stored information (ESI) maintained by the United States Immigration and Customs Enforcement Agency and several other federal agencies (agencies) (defendants). Although the agencies spent thousands of hours keyword searching their databases and turned up massive amounts of responsive ESI, the organization sued the agencies in federal court over the alleged inadequacy of the agencies’ FOIA responses. All of the agencies based their searches on eight keywords. Although some agencies were able to provide the court with detailed information regarding the supervision of their records custodians’ application of the keywords, other agencies asked the court to trust that their custodians used the keywords appropriately and effectively. The agencies moved for summary judgment.
Rule of Law
Holding and Reasoning (Scheindlin, J.)
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