Heritage Foundation v. U.S. Department of Justice

District Court, District of Columbia·Decided July 23, 2025·No. Civil Action No. 2023-0327·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA _________________________________________ ) HERITAGE FOUNDATION, et al., ) ) Plaintiffs, ) ) v. ) Case No. 23-cv-327 (APM) ) DEPARTMENT OF JUSTICE ) ) ) Defendant. ) _________________________________________ )

MEMORANDUM OPINION

I.

In September 2022, Plaintiffs Heritage Foundation and Mike Howell submitted a two-part

request under the Freedom of Information Act (FOIA) to Defendant U.S. Department of Justice,

seeking information relating to labor hours expended by special agents of the Washington Field

Office during the summer months of 2020 (May 21, 2020, to August 31, 2020). Part One of request

sought records “sufficient to establish” the total number of labor hours worked during that period,

and Part Two demanded records “sufficient to establish” the hours devoted “to investigations of

any and all matters related to left wing domestic terrorism . . . includ[ing] ‘violent, extremist

agendas-anarchists like Antifa and other agitators’ arising from the summer 2020 riots.” Def.’s

Mot. for Summ. J., ECF No. 13 [hereinafter Def.’s Mot.], Decl. of Michael G. Seidel, ECF No.

13-1 [hereinafter Seidel Decl.], ¶ 5, Ex. A. The FBI produced a one-page record in response to the

first part of the request, but as to the second advised Plaintiff:

The FOIA does not require federal agencies to answer inquiries, create records, conduct research, or draw conclusions concerning queried data. Rather the FOIA requires agencies to provide access to reasonably described, nonexempt records. The questions posed in the referenced letter are not FOIA requests because they do not comply with the FOIA and its regulations. Therefore, your request is being administratively closed.

Id., Ex. F.

Defendant moves for summary judgment. See Def.’s Mot. Plaintiffs do not contest the

agency’s response to Part One of the request. Mem. in Support of Pls.’ Mot. in Opp’n to Def.’s

Mot., ECF No. 19 [hereinafter Pls.’ Opp’n], at 2 n.1. Their dispute concerns Part Two. At issue is

whether Plaintiffs properly exhausted administrative remedies as to that portion of the demand,

and whether Defendant conducted an adequate search for records. Def.’s Mot. at 8–10; Pls.’ Opp’n

at 9–11.

The court finds that Defendant performed an adequate search with respect to Part Two of

the request. It therefore does not reach the exhaustion issue. See Hidalgo v. FBI, 344 F.3d 1256,

1258 (D.C. Cir. 2003) (stating that “the exhaustion requirement is not jurisdictional because the

FOIA does not unequivocally make it so”). Accordingly, the court will enter judgment in favor of

Defendant.

II.

To demonstrate it conducted an adequate search, an “agency must show that it made a good

faith effort to conduct a search for the requested records, using methods which can be reasonably

expected to produce the information requested.” Oglesby v. U.S. Dep’t of the Army, 920 F.2d 57,

68 (D.C. Cir. 1990). The agency must provide a “reasonably detailed affidavit, setting forth the

search terms and the type of search performed, and averring that all files likely to contain

responsive materials (if such records exist) were searched.” Id. An agency affidavit is accorded a

presumption of good faith if it is “relatively detailed and non-conclusory, and . . . submitted in

good faith.” Eddington v. U.S. Dep’t of Defense, 35 F.4th 833, 837 (D.C. Cir. 2022) (quoting

2 SafeCard Servs., Inc. v. SEC, 926 F.2d 1197, 1200 (D.C. Cir. 1991)). That presumption cannot be

overcome with “purely speculative claims about the existence and discoverability of [the request].”

Id. (quoting SafeCard, 926 F.2d at 1200) (alteration in original). The plaintiff must provide

“‘countervailing evidence’ as to the adequacy of the agency’s search.” Iturralde v. Comptroller of

the Currency, 315 F.3d 311, 314 (D.C. Cir. 2003) (internal citation omitted). “If a review of the

record raises substantial doubt, particularly in view of well defined requests and positive

indications of overlooked materials, summary judgment is inappropriate.” Id. (citation modified).

In this case, Defendant’s declaration from Michael Seidel is entitled to a presumption of

good faith. It is “relatively detailed and non-conclusory” and explains why the FBI produced no

records in response to Part Two of the request. See Eddington, 35 F.4th at 837; Seidel Decl.,

Seidel is the Section Chief of the Record/Information Dissemination Section of the FBI.

Seidel Decl. ¶ 1. He states that, to identify responsive information, the agency turned to the

Performance Management Unit (PMU), Resources Planning Office, in the Office of the Associate

Deputy Director. Seidel Decl. ¶ 23. Seidel explains:

PMU is responsible for organizing and making management data accessible to the FBI to impact decisions on program management, resource allocation and organizational planning. PMU structures and arranges information related to various aspects of the FBI operations and resources, and ensures that crucial data is readily available and easily retrievable when needed.

Id. PMU advised that its ability to report validated hours for specific cases assigned to the

Washington Field Office was “limited.” Id. ¶ 26. FBI agents record hours worked on cases and

associate certain classification codes, but “there is no tracking mechanism for distinguishing cases

related to specific events.” Id. There is no classification code associated with matters such as “left

wing domestic terrorism . . . includ[ing] ‘violent, extremist agendas-anarchists like Antifa and

other agitators’ arising from the summer 2020 riots.” Id. To fulfill Part Two of the request, the

3 FBI “would be required to answer inquiries, create records, conduct research, or draw conclusions

concerning queried data which are not required under FOIA.” Id. ¶ 27. The FBI “does not

maintain the specific data sought by Plaintiffs” in Part Two of their request. Id. ¶ 32.

Plaintiffs submit two critiques of the search. First, grasping on to the word “limited,” which

PMU used to describe its capacity to retrieve labor hours data about specific events, Plaintiffs

assert that the declaration lacks sufficient specificity to establish that responsive data does not

exist. Pls.’ Opp’n at 10. But that contention overlooks Seidel’s explanation that “to fulfill

Plaintiffs[’] request” the agency would have to sift through the available data, analyze it, drawn

inferences from it, and create a new record. Seidel Decl. ¶ 27. The declaration leaves no room for

doubt that data responsive to Part Two does not independently exist.

Second, Plaintiffs fault the agency for not inquiring into whether the data sought “may have

already been compiled” in some other form. Pls.’ Opp’n at 10–11. As Plaintiffs put it: “[T]he FBI

appears to only have searched for source data to produce ‘records sufficient to show’; it appears

they did not search for compilations of that data that answer the same question.” Id. at 11.

But Plaintiffs offer no “countervailing evidence” to believe that such a compilation exists. They

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