Rollins v. United States Department of State
70 F. Supp. 3d 546
D.D.C.2014Background
- Rollins submitted a FOIA request to the State Department in Oct 2012 seeking records about her son Michael Jordan Rollins’s death in Taiwan.
- State acknowledged the request in Nov 2012 but produced records only after suit, in Jan–Feb 2014, totaling 195 documents (158 in full, 37 with redactions).
- Six documents remained contested and were reviewed in camera by the court; the parties limited their challenge to search adequacy and six withholdings.
- The Department located four potential components and described its search terms and methods in detail via declarations from Hackett.
- Rollins argues the search was inadequate because some referenced but undisclosed items (a postal receipt, a telefax cover sheet) were not produced; State contends the search was reasonably calculated to locate all responsive records and that the undisclosed items do not establish inadequacy.
- The court grants State’s motion for summary judgment and denies Rollins’s cross-motion, concluding the search was adequate and the withholdings were proper under Exemptions 5 and 6, with no further non-exempt material required to be produced.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether State’s search was adequate under FOIA | Rollins contends hidden leads show other offices or files should have been searched. | State conducted a reasonable, documented search of four components with appropriate terms. | Yes; search deemed reasonably calculated to uncover all responsive records. |
| Whether State properly withheld portions of six documents under Exemptions 5 and 6 and whether non-exempt material could be segregated | Rollins argues redactions of certain portions were improper and seeks greater disclosure. | State demonstrates redactions fall within deliberative-process and attorney-client privileges (Exemption 5) and privacy concerns (Exemption 6); non-exempt material was segregated where possible. | Yes on both; exemptions applied properly and no additional reasonably segregable non-exempt material. |
Key Cases Cited
- Valencia-Lucena v. Coast Guard, 180 F.3d 321 (D.C. Cir. 1999) (adequacy of a search depends on reasonable calculation to locate records)
- Truitt v. Dep’t of State, 897 F.2d 540 (D.C. Cir. 1990) (standard for reasonable FOIA search)
- Weisberg v. Dep’t of Justice, 745 F.2d 1476 (D.C. Cir. 1984) (FOIA search adequacy and use of detailed declarations)
- Perry v. Block, 684 F.2d 121 (D.C. Cir. 1982) (requirement of reasonable detail in search descriptions)
- Campbell v. Department of Justice, 164 F.3d 20 (D.C. Cir. 1998) (presence of unsearched locations based on leads can show inadequacy)
- Iturralde v. Comptroller of the Currency, 315 F.3d 311 (D.C. Cir. 2003) (failure to produce a specific document does not alone prove search was inadequate)
- Department of Justice v. Reporters Committee for Freedom of the Press, 489 U.S. 749 (U.S. 1989) (FOIA requires agency to sustain its action; de novo review; strong presumption of disclosure)
- Wash. Post Co. v. Dept. of Justice, 456 U.S. 595 (U.S. 1982) (broad interpretation of privacy exemptions under FOIA)