Hedrick v. Federal Bureau of Investigation
216 F. Supp. 3d 84
| D.D.C. | 2016Background
- Plaintiff Robert L. Hedrick, a federal prisoner convicted of child‑pornography offenses, submitted two FOIA requests in August 2013 seeking FBI records about investigations and his contacts with FBI agents.
- The FBI consolidated the requests into one administrative case, searched its Central Records System (CRS)/UNI (and Sentinel for post‑2012 records), and located no main investigative file but located one cross‑reference control file containing a two‑page Form 302 (interview report).
- The FBI released the two‑page Form 302 to Hedrick with redactions under FOIA Exemptions 6 and 7(C); it reported no other responsive records in the control file.
- Hedrick sued pro se, alleging inadequate search, withholding of additional records (including a purported smuggling/national‑security matter), and that the produced Form 302 was fabricated or planted.
- The FBI moved for summary judgment, submitting the Hardy declaration describing the CRS/UNI/Sentinel indexing and search methodology; the court credited that showing, found the search reasonable, and granted summary judgment for the FBI.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of search | Hedrick: FBI failed to search specific field offices and thus did not locate all responsive records. | FBI: Searched CRS/UNI (and Sentinel as applicable); those indices cover HQ and field offices and were reasonably calculated to locate records. | Court: Search adequate; CRS/UNI search reasonably calculated to locate responsive records. |
| Existence of additional or destroyed records | Hedrick: Additional records (esp. re: alleged smuggling/national‑security tips) exist or were hidden/destroyed. | FBI: Hardy declaration presumed in good faith; speculation cannot rebut that showing. | Court: Speculation insufficient to overcome presumption of good faith; no substantial doubt created. |
| Authenticity of produced Form 302 | Hedrick: Produced Form 302 is false/forged and was planted in the file. | FBI: Production of documentary records under FOIA does not require agency authentication; authenticity challenges are beyond FOIA scope. | Court: Authenticity/content disputes are outside FOIA relief; Hedrick’s assertions do not affect adequacy analysis. |
| Segregability of non‑exempt information | Hedrick: Implicitly sought full control file and more disclosure. | FBI: Released all reasonably segregable material and redacted limited PII under Exemptions 6 and 7(C). | Court: FBI satisfied segregability obligation; redactions appropriate and remaining material withheld properly. |
Key Cases Cited
- Oglesby v. U.S. Dep't of the Army, 920 F.2d 57 (D.C. Cir. 1990) (agency must make a good‑faith search using methods reasonably calculated to locate requested records)
- Iturralde v. Comptroller of the Currency, 315 F.3d 311 (D.C. Cir. 2003) (adequacy of FOIA search judged by reasonableness of methods, not by results)
- SafeCard Servs., Inc. v. SEC, 926 F.2d 1197 (D.C. Cir. 1991) (agency affidavits enjoy presumption of good faith and speculative allegations cannot rebut them)
- Military Audit Project v. Casey, 656 F.2d 724 (D.C. Cir. 1981) (summary judgment for agency acceptable when affidavits describe justifications with reasonably specific detail and are not contradicted)
- Mead Data Cent., Inc. v. Dep't of the Air Force, 566 F.2d 242 (D.C. Cir. 1977) (non‑exempt portions of documents must be disclosed unless inextricably intertwined with exempt portions)
- Anderson v. Liberty Lobby, 477 U.S. 242 (U.S. 1986) (summary judgment standard: no genuine issue of material fact)