James Madison Project v. Central Intelligence Agency

CourtDistrict Court, District of Columbia
DecidedAugust 27, 2025
DocketCivil Action No. 2022-0321
StatusPublished

This text of James Madison Project v. Central Intelligence Agency (James Madison Project v. Central Intelligence Agency) 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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James Madison Project v. Central Intelligence Agency, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JAMES MADISON PROJECT, et al.,

Plaintiffs,

v. Civil Action No. 1:22-cv-00321 (CJN)

CENTRAL INTELLIGENCE ACENCY,

Defendant.

MEMORANDUM OPINION

In this FOIA action, plaintiffs seek to compel the CIA’s disclosure of various elements of

its intelligence assessment concerning the mysterious health condition commonly known as

Havana syndrome. The CIA moves for summary judgment on the grounds that it has conducted

an adequate search for responsive records and produced all those that are not exempt. Having now

reviewed the CIA’s supplemental classified declaration, the Court agrees and grants the CIA’s

motion.

I. Background

A. Factual Background

In recent years, hundreds of federal government officials and their family members have

reported experiencing “anomalous health incidents” (AHIs) while at their foreign and domestic

posts. ECF No. 4 (Compl.) ¶ 7; ECF No. 22-1 at 3, 7–8. The reported symptoms vary, but tend

to include headaches, dizziness, nausea, and cognitive impairment, often preceded by the

perception of a loud noise or a change in pressure. See ECF No. 22-1 at 7. Because AHIs were

first reported by officials stationed at the U.S. Embassy in Cuba, they have been colloquially

referred to as “Havana syndrome.” Id.

1 After news of the AHIs became public, some media outlets and scientists speculated that

they could be the result of “directed-energy weapons” deployed against American spies and

diplomats by a foreign adversary. See, e.g., Compl. ¶ 7 (citing, inter alia, William J. Broad,

Microwave Weapons Are Prime Suspect in Ills of U.S. Embassy Workers, N.Y. TIMES, Sep. 1,

2018). But on January 19, 2022, media reporting announced that the CIA had determined that

“most cases” of AHIs were “unlikely” to have been caused by “a sustained global campaign by a

foreign power” and could instead be explained by “other causes”—like environmental factors,

undiagnosed medical conditions, or stress. See id. ¶ 8; ECF No. 14-1 (Blaine Decl.) ¶ 14; ECF

No. 22-1 at 3. Multiple publications described the CIA’s determination as an “interim” finding,

and the CIA Director himself stated that, while the agency had “reached some significant interim

findings,” it was “not done.” Compl. ¶¶ 8–9 (collecting sources); Blaine Decl. ¶ 14. But USA

Today reported on a tip from a U.S. intelligence official that, while the CIA’s January 2022 report

was “technically classified as an interim assessment,” it was in fact a “definitive and official

agency finding based on months of intensive investigation.” Compl. ¶ 9 (citing Josh Meyer, CIA

rules out hostile foreign power behind medical symptoms known as ‘Havana Syndrome’, USA

TODAY, Jan. 20, 2022).

A few weeks later, on February 2, 2022, the Office of the Director of National Intelligence

“announced that a panel convened by the U.S. intelligence community had concluded [that] the

core symptoms of [certain] unsolved [AHIs] could be caused by pulsed electromagnetic or

ultrasonic energy.” Id. ¶ 10 (emphasis added); see also ECF No. 22-1 at 6–7. “A declassified

executive summary of the intelligence community’s assessment found [that] the effects of the

mysterious illness are ‘genuine and compelling,’ and that psychological factors or mass hysteria

2 on their own could not account for the core characteristics of [unsolved] [AHIs].” Compl. ¶ 10;

see also ECF No. 22-1 at 9.

In March 2023, however, the Director of National Intelligence released an “updated

assessment” affirming that “most [intelligence community] agencies have now concluded that it is

‘very unlikely’ [that] a foreign adversary is responsible for the reported AHIs,” albeit with

“varying confidence levels.” ECF No. 20-1 at 2, 5. The CIA Director stated that he “st[oo]d firmly

behind the . . . findings” of the intelligence community, and described the CIA’s contributions to

that analytic effort as “one of the largest and most intensive investigations in the Agency’s history.”

Id. at 12. (The House Permanent Select Committee on Intelligence, in contrast, maintains that the

intelligence community’s 2023 conclusions on AHIs are of questionable accuracy and “not based

on the available facts.” ECF No. 22-1 at 3–4. It thus continues to pursue its own “efforts to

understand AHIs.” Id.)

B. Procedural History

On January 21, 2022, plaintiffs James Madison Project—a government accountability

organization—and Brian Karem—an investigative reporter—submitted a FOIA request to the CIA

that referenced the January 19, 2022 media reporting on the CIA’s “interim” findings about AHIs

and sought “records . . . surrounding the issuance of” that “intelligence assessment.” 1 Blaine Decl.

Ex. A at 1–2. Relevant here, plaintiffs requested three specific categories of documents: (1) a

“copy of the Assessment,” (2) “[a]ll intelligence information relied upon in formulating

1 Citing to the aforementioned USA Today article, the request asserted that “[a]lthough the Assessment was widely described as an ‘interim’ report, it actually was not.” Blaine Decl. Ex. A at 2.

3 conclusions in the Assessment,” and (3) “[a]ll factual, medical and/or scientific findings made in

the course of formulating the conclusions in the Assessment.” 2 Id. at 2.

The CIA ultimately responded to plaintiffs’ request as follows. Regarding part 1, which

sought the “assessment” itself, the CIA stated that its search had identified three responsive

documents. Blaine Decl. ¶ 14. The CIA released two in part, but withheld the third in full. Id.

¶ 15. As to parts 2 and 3, which sought the intelligence and factual information underlying the

assessment, the CIA informed plaintiffs that it had “identified at least one record responsive to

th[o]se parts,” but could “[]not provide the number of responsive records or further describe them

without revealing information that is itself protected from disclosure.” Blaine Decl. Ex. C at 1.

As the basis for all its withholdings, including its “no number, no list” response to parts 2 and 3,

the CIA cited FOIA Exemptions 1 and 3, which cover classified records and records specifically

exempt from disclosure by statute. Blaine Decl. ¶¶ 15–21; see 5 U.S.C. §§ 552(b)(1), (3).

By the time plaintiffs received the CIA’s response, they had already filed this lawsuit. 3 See

Compl. at 6–7. Once the CIA’s production was complete, the agency moved for summary

judgment on the grounds that it had conducted an adequate search and had released all responsive

and non-exempt records. See ECF No. 14 (Mot.) at 2. Its motion was supported by a declaration

from Vanna Blaine, a senior CIA official with original classification authority tasked with

2 Plaintiffs also requested “[a]ll documentation memorializing talking points and briefing notes for U.S. Government personnel discussing the Assessment with media outlets, individual Members of Congress[,] or staff with the House Permanent Select Committee on Intelligence/Senate Select Committee on Intelligence.” Blaine Decl. Ex. A at 2. But that element of the request is not at issue in this litigation. See ECF No. 11 ¶ 1. 3 Plaintiffs initially sought expedited processing of their FOIA request, Compl. at 5–6, but withdrew that count after the CIA had processed all parts of the request at issue. See ECF No.

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