Informed Consent Action Network v. National Aeronautics & Space Administration

CourtDistrict Court, District of Columbia
DecidedSeptember 29, 2025
DocketCivil Action No. 2024-3062
StatusPublished

This text of Informed Consent Action Network v. National Aeronautics & Space Administration (Informed Consent Action Network v. National Aeronautics & Space 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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Informed Consent Action Network v. National Aeronautics & Space Administration, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

INFORMED CONSENT ACTION NETWORK,

Plaintiff,

v. Civil Action No. 24 - 3062 (LLA)

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION,

Defendant.

MEMORANDUM OPINION

Plaintiff Informed Consent Action Network (“ICAN”) brings this action against the

National Aeronautics and Space Administration (“NASA”), alleging violations of the Freedom of

Information Act (“FOIA”), 5 U.S.C. § 552, arising out of its request for certain records, ECF No. 1.

This matter is before the court on NASA’s motion for summary judgment, ECF No. 10, and

ICAN’s cross-motion for summary judgment, ECF No. 13. For the reasons explained below, the

court will grant NASA’s motion for summary judgment and deny ICAN’s cross-motion for

summary judgment.

I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY

ICAN is a nonprofit news media organization with a mission of “put[ting] health

information in the hands of the public to enable informed consent concerning medical decisions.”

ECF No. 12, at 1-2; see ECF No. 15-1 ¶ 33. NASA is a federal agency that “conduct[s]

cutting-edge research to advance technology and aeronautics.” Nat’l Aeronautics & Space Admin., About NASA.1 NASA owns the Jet Propulsion Laboratory (“JPL”), a federally funded

research and development center (“FFRDC”) based at the California Institute of Technology

(“Caltech”). ECF No. 15-1 ¶¶ 1-2. Originally founded in 1936 by Caltech researchers, the JPL

today exists to support the “long-term research and development needs of NASA missions when

those needs cannot be met as effectively by existing in-house federal or contractor resources.” Id.

¶ 3;2 see 48 C.F.R. § 35.017(a)(2) (2024); ECF No. 10-2, at 2 ¶ 4.3

In October 2023, ICAN submitted a FOIA request to NASA, seeking:

All communications sent or received by Riley Duren and Erik Conway from January 1, 2018 through the date of the search that contain the term(s) “geoengineer*,” “climate intervention,” “solar radiation management,” “SRM,” “stratospheric aerosol injection,” “SAI,” “SABRE,” and/or “SCOPEX.”

* = Boolean search

ECF No. 15-1 ¶ 10; see ECF No. 1-1, at 1-2. The next month, NASA sent ICAN a letter

acknowledging the request, ECF No. 15-1 ¶ 11, and stating that its “Prime Contractor, California

Institute of Technology (Caltech), need[ed] additional time to process [ICAN’s] request,” ECF

No. 1-2, at 1.4 In February 2024, NASA updated ICAN on the status of the search, explaining that

1 Available at https://perma.cc/8EQM-82KF. 2 While ICAN states that it cannot substantiate this claim without discovery, ECF No. 12-1 ¶ 3, it is undisputed that the JPL is a FFRDC, see id. ¶ 1, and the rest of this assertion flows from the statutory definition of a FFRDC, see 48 C.F.R. § 35.017(a)(2). 3 When citing ECF Nos. 10-2 and 10-3, the court uses the page numbers generated by CM/ECF, rather than each document’s internal pagination. 4 When NASA receives a FOIA request for records related to the JPL’s operations, its Office of Jet Propulsion Laboratory Management and Oversight makes a formal request to the JPL FOIA Liaison—a Caltech employee—to conduct a search for responsive records. ECF No. 10-2, at 2 ¶ 5.

2 it had asked the FOIA Liaison at Caltech to conduct a search for the requested records, and the

Liaison had responded:

[T]here are no responsive government records. There are contractor records that do not include NASA in the distribution of those contractor records, but these were not provided pursuant to H-16 (b)(1)(i) of NASA Prime Contract 80NMO0018D0004. Our search process included searching the official office of record using all of the request’s specified search terms and full time period.

ECF No. 1-3, at 2; see ECF No. 15-1 ¶¶ 17, 45. NASA’s letter further clarified that “[n]ot all data

at the Jet Propulsion Laboratory are government records”; that “[c]ontractor records are not subject

to the FOIA in that they are not Government records, not in our control, and beyond the reach of

a NASA FOIA request”; and that the “personnel named in [ICAN’s] request are not NASA

Government employees.” ECF No. 1-3, at 2-3.

In May 2024, ICAN timely appealed, ECF No. 1-4, and the next month, NASA confirmed

receipt of the appeal request, ECF No. 1-5; see ECF No. 15-1 ¶¶ 18, 47. ICAN filed this action in

October 2024, ECF No. 1, without having received a final determination as to its appeal, see ECF

No. 15-1 ¶¶ 18, 48-49. In December 2024, the parties met and conferred, and ICAN clarified that:

(1) it sought only emails and chats responsive to its request; and (2) it was not requesting a search

of the systems of NASA employees for responsive emails or chats with the named Caltech

employees. ECF No. 15-1 ¶¶ 19-22. In 2025, the parties filed cross-motions for summary

judgment, ECF Nos. 10, 13, which have been fully briefed, ECF Nos. 10, 12, 13, 15 to 17.

II. LEGAL STANDARDS

The purpose of FOIA is “to pierce the veil of administrative secrecy and to open agency

action to the light of public scrutiny.” Am. C.L. Union v. U.S. Dep’t of Just., 655 F.3d 1, 5

(D.C. Cir. 2011) (quoting Dep’t of Air Force v. Rose, 425 U.S. 352, 361 (1976)). FOIA “vests

3 jurisdiction in federal district courts to enjoin an ‘agency from withholding agency records and to

order the production of any agency records improperly withheld from the complainant.’”

Kissinger v. Reps. Comm. for Freedom of the Press, 445 U.S. 136, 139 (1980) (quoting 5 U.S.C.

§ 552(a)(4)(B)).

“[T]he vast majority of FOIA cases can be resolved on summary judgment.” Brayton v.

Off. of the U.S. Trade Representative, 641 F.3d 521, 527 (D.C. Cir. 2011). Summary judgment

may be awarded to the agency if it can demonstrate that no material facts are in dispute, that it

conducted an adequate search for responsive records, and that each record has either been produced

or is exempt from disclosure. Jud. Watch, Inc. v. U.S. Dep’t of Homeland Sec., 59 F. Supp. 3d

184, 189 (D.D.C. 2014); see Fed. R. Civ. P. 56(a). “The burden is on the agency to demonstrate,

not the requester to disprove, that the materials sought are not ‘agency records’ or have not been

‘improperly’ ‘withheld.’” U.S. Dep’t. of Just. v. Tax Analysts, 492 U.S. 136, 142 n.3 (1989)

(citation omitted).

In considering a motion for summary judgment, the court may rely on declarations,

affidavits, and other documents that “describe the justifications for nondisclosure with reasonably

specific detail . . . and are not controverted by either contrary evidence in the record nor by

evidence of agency bad faith.” Larson v.

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