Citizens for Responsibility and Ethics in Washington v. National Archives and Records Administration

CourtDistrict Court, District of Columbia
DecidedMarch 12, 2021
DocketCivil Action No. 2020-0739
StatusPublished

This text of Citizens for Responsibility and Ethics in Washington v. National Archives and Records Administration (Citizens for Responsibility and Ethics in Washington v. National Archives and Records Administration) 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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Citizens for Responsibility and Ethics in Washington v. National Archives and Records Administration, (D.D.C. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

_________________________________________ ) CITIZENS FOR RESPONSIBILITY ) AND ETHICS IN WASHINGTON et al., ) ) Plaintiffs, ) ) v. ) Case No. 20-cv-00739 (APM) ) NATIONAL ARCHIVES AND RECORDS ) ADMINISTRATION et al., ) ) Defendants. ) _________________________________________ ) MEMORANDUM OPINION

I. INTRODUCTION

In December 2019, the National Archives and Records Administration (“NARA”)

approved a request from U.S. Immigration and Customs Enforcement (“ICE”) to schedule the

disposal of certain agency records for which ICE no longer had a business use. Plaintiffs have

challenged NARA’s approval of that request as arbitrary and capricious, an abuse of discretion,

and contrary to law. The parties have cross-moved for summary judgment. For the reasons that

follow, the court grants in part and denies in part each motion.

II. BACKGROUND

A. Legal Background

The Federal Records Act provides the legal framework for the collection, preservation, and

disposal of records produced by the federal government. As relevant here, the Act requires that

federal agencies “make and preserve records containing adequate and proper documentation of the

organization, functions, policies, decisions, procedures, and essential transactions of the agency . . . to protect the legal and financial rights of the Government and of persons directly affected by

the agency’s activities.” 44 U.S.C. § 3101. The Federal Records Act entrusts the Archivist, who

is the head of NARA, to provide “guidance and assistance to Federal agencies” to ensure that such

federal records are properly preserved. See id. § 2904(a).

The Archivist works cooperatively with federal agencies to determine which records an

agency must preserve in the archives and which records may be segregated and disposed because

of their “temporary value.” See id. § 3102(3). Agency heads request “disposition authority”—

permission to discard records—from the Archivist and submit to the Archivist plans to dispose of

records that are no longer “needed by [the agency] in the transaction of its current business and

that do not appear to have sufficient administrative, legal, research, or other value to warrant their

further preservation.” Id. § 3303(2). These plans can include “schedules proposing the disposal”

of records that lose their “administrative, legal, research, or other value” over time and do not

qualify for permanent retention. Id. § 3303(3). The Archivist “examine[s] the lists and schedules”

and, following a public notice and comment period, determines if any of the records “have

sufficient, administrative, legal, research, or other value to warrant their continued preservation.”

Id. § 3303a(a).

Pursuant to its statutory authority to “establish standards for the selective retention of

records of continuing value,” id. § 2905(a), NARA has promulgated an “Appraisal Policy” that

“sets out the strategic framework, objectives, and guidelines that [it] uses to determine whether

Federal records have archival value.” Nat’l Archives & Records Admin., Appraisal Policy of the

National Archives § 1 (Sept. 2007), https://www.archives.gov/records-mgmt/scheduling/

appraisal#policy [hereinafter Appraisal Policy]. As the Appraisal Policy states: “Records

appraisal is not a rote exercise. It requires informed judgments, knowledge of and sensitivity to

2 researchers’ interests, recognition of resource considerations, and a willingness to acknowledge

and understand comments and suggestions from diverse perspectives.” Id. The Appraisal Policy

sets forth how appraisers are to make such informed judgments.

The Policy explains that, as the first step to appraising records, NARA “collect[s] essential

evidence from Federal agencies.” Id. § 6. “Essential evidence” is broken down into three

categories: (1) “[r]ecords that document the rights of citizens” and enable citizens “to establish

their identities, protect their rights, and claim their entitlements”; (2) “[r]ecords that document

actions of Federal officials” and “enable them to explain past decisions, form future policy, and be

accountable for consequences”; and (3) “[r]ecords that document the national experience” and

“provide the means for evaluating the effects of Federal actions on the nation and for understanding

its history, science, and culture, including the man-made and natural environment.” Id. Not all

“essential evidence” requires permanent retention, and “the essential evidence categories” serve

merely “as the beginning point for appraisal.” Id. §§ 6–7.

Sections 7 and 8 of the Appraisal Policy provide guidance on how, within the three

categories of essential evidence, NARA identifies records that require permanent preservation.

Of the records constituting essential evidence, NARA seeks to permanently retain (1) records

whose “importance . . . for protecting legal rights endures despite the passage of time,” (2) records

“containing significant documentation of Government activities” that are “essential to

understanding and evaluating Federal actions,” and (3) records that are “essential to understanding

the role of the Federal Government and the history of our nation, its people, and the environment.”

Id. § 7. NARA treats these categories as a “high-level strategic framework” for identifying

permanent records, and section 8 in turn provides six more granular categories of records that

should be permanently retained. See id. § 8. These categories include, for example, records that

3 “[r]etain their importance for documenting legal status, rights and obligations of individuals,

groups, organizations, and governmental bodies despite the passage of time”; “[p]rovide evidence

of significant policy formulation and business processes of the Federal Government”; and

“[p]rovide evidence of Federal deliberations, decisions, and actions relating to major social,

economic, and environmental issues,” among many others. Id.

While sections 7 and 8 of the Appraisal Policy provide categories of documents that

warrant permanent preservation, those categories are descriptively quite broad, and NARA “uses

the general guidelines outlined in Appendix 1” as more concrete criteria for “determining which

records support its appraisal objectives and thus warrant permanent retention.” Id. § 9. Appendix 1

consists of a series of questions that “NARA staff must address” in reaching a recommendation to

the Archivist. Id. app. 1 (emphasis added). The Appendix notes that “[a]pplying the guidelines to

specific cases will not be a mechanical process akin to adding up points or checking boxes,” but

that the guidelines therein are intended to “make decision making easier” and generate “more

consistent appraisal judgments.” Id.

Of significance to this case is Appendix 1’s first archival guideline. It asks: “How

significant are the records for research?” Id. This question, the guidance notes, “is the most

difficult variable to determine” because “[w]hat is of relatively low research use today may become

of great research use in the future.” Id. Despite the difficulty of accurately appraising a

document’s research value, “it is important to consider this question in making appraisal

decisions.” Id.

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Citizens for Responsibility and Ethics in Washington v. National Archives and Records Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/citizens-for-responsibility-and-ethics-in-washington-v-national-archives-dcd-2021.