Center to Advance Security in America v. United States Agency for International Development
Civil Action No. 2024-3505
D.D.C.Mar 11, 2025Background
- The Center to Advance Security in America filed a FOIA suit against the U.S. Agency for International Development (USAID) for not meeting statutory deadlines to process records requests.
- FOIA requires agencies to respond to requests and appeals within 20 days and to make records available promptly, facilitating efficient public access to information.
- USAID sought to stay the proceedings, citing an agency-wide reduction-in-force that cut FOIA staffing by half and left only a handful of personnel to process requests.
- USAID did not cite external causes, such as lack of funds or an unexpected surge in FOIA requests, for its inability to meet statutory timelines.
- The plaintiff did not oppose the requested stay.
- The court granted a stay but emphasized this was only because the motion was unopposed and did not set a precedent for opposed requests in similar situations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether USAID should be granted a stay of FOIA proceedings due to internal staffing reductions | No opposition to stay | Staffing reductions severely limit FOIA processing ability | Stay granted as unopposed |
| Whether agency-initiated staffing cuts qualify as "exceptional circumstances" under FOIA | Not addressed | Reduction-in-force justifies relief from deadlines | Court skeptical; no finding on merits |
| Applicability of FOIA timeline exceptions when causes are internal and not due to external impediments | Not addressed | Implied internal causes suffice for exception | Court expresses strong skepticism |
| Status of initial status hearing and next procedural steps | No objection | Hearing should be vacated, report later on status | Hearing vacated, joint report ordered |
Key Cases Cited
- U.S. Dep’t of State v. Ray, 502 U.S. 164 (1991) (explains FOIA’s purpose to ensure transparency)
- Dep’t of Air Force v. Rose, 425 U.S. 352 (1976) (FOIA promotes public scrutiny of agency action)
- August v. FBI, 328 F.3d 697 (D.C. Cir. 2003) (emphasizes FOIA’s statutory goal of prompt, full disclosure)
- Open America v. Watergate Special Prosecution Force, 547 F.2d 605 (D.C. Cir. 1976) (discusses FOIA’s statutory exceptions and safety valve for exceptional circumstances)