American Immigration Council v. Executive Office for Immigration Review

CourtDistrict Court, District of Columbia
DecidedFebruary 14, 2025
DocketCivil Action No. 2023-1952
StatusPublished

This text of American Immigration Council v. Executive Office for Immigration Review (American Immigration Council v. Executive Office for Immigration Review) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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American Immigration Council v. Executive Office for Immigration Review, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

AMERICAN IMMIGRATION COUNCIL, : et al., : : Plaintiffs, : Civil Action No.: 23-1952 (RC) : v. : Re Document Nos.: 25, 26 : EXECUTIVE OFFICE FOR IMMIGRATION : REVIEW, : : Defendant. :

MEMORANDUM OPINION

GRANTING IN PART AND DENYING IN PART DEFENDANT’S MOTION FOR SUMMARY

JUDGMENT; GRANTING IN PART AND DENYING IN PART PLAINTIFFS’ MOTION FOR SUMMARY

JUDGMENT

I. INTRODUCTION

Plaintiffs are nonprofit organizations that advocate for fair and just administration of

United States immigration laws. These organizations claim that immigration judges sometimes

advance the date of immigration court hearings, and that this practice interferes with noncitizens’

access to counsel during those proceedings. Plaintiffs filed a Freedom of Information Act

(“FOIA”) request with the Executive Office of Immigration Review (“EOIR”) for policy

documents regarding advancement of hearings, motions to continue, and related issues. After

EOIR failed to respond, Plaintiffs filed this lawsuit. The agency subsequently conducted manual

and keyword searches of email accounts belonging to current and former Chief Immigration

Judges. EOIR also searched an intranet site location where policy documents are commonly

stored. Plaintiffs claim that EOIR construed the scope of its request too narrowly, and that its search for responsive documents was inadequate. EOIR asserts that it properly construed

Plaintiffs’ FOIA request and that its search was reasonable and adequate. The Court concludes

that EOIR properly understood the scope of Plaintiffs’ FOIA request with respect to records

sought within the Office of the Chief Immigration Judge (“OCIJ”). EOIR nonetheless

misinterpreted the FOIA request to exclude records held by Assistant Chief Immigration Judges

(“ACIJs”), and additional locations are likely to contain documents responsive to the request. As

such, the Court grants in part and denies in part each party’s motion for summary judgment and

directs the agency to conduct a supplemental search for responsive records.

II. FACTUAL BACKGROUND

Plaintiffs submitted a FOIA request to EOIR on October 28, 2022, seeking “records of

guidelines, procedures, protocols, or policies relating to” five subcategories of procedures

followed by immigration courts and judges, reaching back to January 1, 2017. Def.’s Statement

of Undisputed Material Facts (“SUMF”) ¶¶ 1–2, ECF No. 25-2. 1 Those subcategories included

(1.a.) “[i]mmigration courts’ process and criteria used to advance the date of individual merit

hearings”; (1.b.) “[i]mmigration judges’ adjudication of motions to continue individual merit

hearings when the basis for continuances relate to” an attorney’s “case-related scheduling

conflict” or “workload or case-related conflicts that may prevent case preparation”; (1.c.)

“[i]mmigration courts’ process for notifying respondents, respondents’ representatives, or both,

that individual merit hearings have been advanced”; (1.d.) “[c]ourt personnel’s process for

selecting a new hearing date when an individual merit hearing is advanced”; and (1.e) “[t]he

1 Item 2 of the FOIA request sought data indicating the number of cases advanced by immigration courts since January 1, 2020. See SUMF ¶ 2. As EOIR provided the data, that request is no longer at issue in this lawsuit. See Pls.’ Mem. in Supp. of Mot. Summ. J. and in Partial Opp’n to Def.’s Mot. Summ. J. (“Pls.’ Mot.”) at 4 n.3, ECF No. 26-1.

2 agency’s implementation of the November 27, 2020, Notice of Proposed Rulemaking titled

‘Good Cause for a Continuance in Immigration Proceedings.’” Id. ¶ 2.

After EOIR failed to produce records in response to the FOIA request, Plaintiffs filed this

lawsuit on July 6, 2023. See Compl., ECF No. 1. EOIR understood the FOIA request to seek

“records that constitute officially issued and centrally disseminated guidelines, procedures,

protocols, or policies pertaining to the listed subitems.” Santiago Decl. ¶ 15, ECF No. 25-3.

EOIR reasoned that responsive guidelines and policies would be disseminated by OCIJ, id. ¶ 18,

and that then-Regional Deputy Chief Immigration Judge Sheila McNulty’s email account “would

be included on emails concerning guidelines, procedures, protocols or policies of the type

requested in the FOIA request,” id. ¶ 19. Judge McNulty performed what EOIR describes as a

“manual search of her email” that located two responsive records. Id. ¶ 20. EOIR also

conducted a search for publicly available guideline and policy documents, identifying 11

responsive records. Id. ¶ 21. After this lawsuit was filed, EOIR conducted a supplemental

search of email accounts belonging to Judge McNulty, who had since been appointed as Chief

Immigration Judge, and her two predecessors reaching back to September 2016. Id. ¶¶ 26–28.

These searches returned an aggregate of 323 items, id. ¶¶ 27, 29, “and the same emails that were

previously identified from the manual search described in paragraph 20 above were the only

records identified as responsive to the request.” Id. ¶ 29. EOIR declined to search for records

responsive to subpart 1.e. of the FOIA request—which sought policy and procedure documents

implementing a proposed rule—because “it was determined that the notice of proposed

rulemaking had not, as of the time of the search in response to the FOIA request, resulted in a

final rulemaking.” Id. ¶ 22.

3 Following further filings in this case, EOIR conducted an additional search of its

“intranet site for guidelines, procedures, protocols and policies” by surveying the Administration

and Policy tab, “where policies related to immigration courts would be stored.” Suppl. Santiago

Decl. ¶ 6, ECF No. 29-2. This search identified a single link to EOIR’s public-facing website,

which included documents EOIR had already provided to Plaintiffs. Id.

EOIR filed a motion for summary judgment, arguing that its search was adequate, that it

properly invoked FOIA Exemption 6 regarding certain employees’ email addresses, and that it

complied with FOIA’s segregability requirement. See generally Def.’s Mot. Summ. J. (“Def.’s

Mot.”), ECF No. 25-1. Plaintiffs filed a cross-motion for summary judgment, asserting that

EOIR improperly narrowed the scope of its FOIA request, that the agency did not search all

repositories likely to contain responsive records, and that its searches were not reasonably

calculated to uncover all responsive documents. See generally Pls.’ Mem. in Supp. of Mot.

Summ. J. and in Partial Opp’n to Def.’s Mot. Summ. J. (“Pls.’ Mot.”), ECF No. 26-1

III. LEGAL STANDARD

The Freedom of Information Act is meant “to pierce the veil of administrative secrecy

and to open agency action to the light of public scrutiny.” U.S. Dep’t of State v. Ray, 502 U.S.

164, 173 (1991) (quoting Dep’t of Air Force v. Rose, 425 U.S. 352, 361 (1976)). It “directs that

‘each agency, upon any request for records . . . shall make the records promptly available to any

person’ unless the requested records fall within one of the statute’s nine exemptions.” Loving v.

Dep’t of Def., 550 F.3d 32, 37 (D.C. Cir. 2008) (quoting 5 U.S.C. § 552

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