Jesse SKINNER, Plaintiff, v. UNITED STATES DEPARTMENT OF JUSTICE, Et Al., Defendants, 893 F. Supp. 2d 109

Skinner filed a FOIA action against the United States Department of Justice and related agencies; BATFE moved for summary judgment on withholding the TECS printout.
The sole issue is USCIS’s redaction of information from a one-page TECS screen printout concerning Skinner.
The TECS printout contains personally identifiable information and law-enforcement details from the TECS system (DHS/CBP) about Skinner, including identifiers, address, date of birth, and operational details.
USCIS originally relied on Exemptions 2 and 7(E) to redact certain items; after Milner v. Navy, USCIS abandoned Exemption 2 and relied on Exemption 7(E) instead.
TECS is a tightly controlled, interagency database with restricted access and security measures; disclosure of internal computer access codes could enable circumvention.
The Court grants the BATFE’s renewed motion for summary judgment, concluding that Exemption 7(E) justifies withholding the TECS access codes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether TECS access codes were properly withheld under Exemption 7(E).	Skinner seeks disclosure and challenges redactions surrounding TECS data.	BATFE and USCIS have demonstrated that TECS access codes reveal law enforcement techniques and could risk circumvention.	Yes; withholding under Exemption 7(E) is appropriate.

Morley v. Central Intelligence Agency, 453 F. Supp. 2d 137 (D.D.C. 2006) (withholding related to security clearances and investigations to prevent circumvention)
Blackwell v. Federal Bureau of Investigation, 646 F.3d 37 (D.C. Cir. 2011) (low bar to justify withholding under Exemption 7(E); risk-based standard)
Mayer Brown LLP v. Internal Revenue Service, 562 F.3d 1190 (D.C. Cir. 2009) (explains the reasonable risk of circumvention standard for Exemption 7(E))