Legal Eagle, LLC v. National Security Council Records Access and Information Security Management Directorate

CourtDistrict Court, District of Columbia
DecidedMarch 18, 2021
DocketCivil Action No. 2020-1732
StatusPublished

This text of Legal Eagle, LLC v. National Security Council Records Access and Information Security Management Directorate (Legal Eagle, LLC v. National Security Council Records Access and Information Security Management Directorate) 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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Legal Eagle, LLC v. National Security Council Records Access and Information Security Management Directorate, (D.D.C. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

LEGAL EAGLE, LLC, : : Plaintiff, : Civil Action No.: 20-1732 (RC) : v. : Re Document Nos.: 7, 13, 21, 27 : NATIONAL SECURITY COUNCIL : RECORDS ACCESS AND : INFORMATION SECURITY : MANAGEMENT DIRECTORATE, et al., : : Defendants. :

MEMORANDUM OPINION

GRANTING DEFENDANTS’ PARTIAL MOTION TO DISMISS; DENYING PLAINTIFF’S MOTION FOR PARTIAL SUMMARY JUDGMENT; GRANTING DEFENDANTS’ MOTION FOR PARTIAL SUMMARY JUDGMENT; DENYING PLAINTIFF’S MOTION TO STRIKE

I. INTRODUCTION

In this case brought pursuant to the Freedom of Information Act (“FOIA”), Plaintiff

Legal Eagle, LLC (“Legal Eagle”), a business that runs a YouTube channel focused on legal

issues, seeks records related to the prepublication review of Former National Security Adviser

John Bolton’s book The Room Where It Happened. Legal Eagle has filed an Amended

Complaint with twenty-one causes of action, all brought under FOIA, related to its various

requests for records and requests for expedited processing. Legal Eagle named as Defendants

the National Security Council Records Access and Information Security Management

Directorate (“RAISMD”), the Central Intelligence Agency, the Department of Defense, the

Department of Justice (“DOJ”), the Department of State, the National Archives and Records

Administration, and the Office of the Director of National Intelligence (together “Defendants”).

RAISMD has moved to dismiss the counts against it, arguing that under binding D.C. Circuit precedent, the National Security Council (“NSC”), and any of its subcomponents, are not subject

to FOIA. Also before the Court are Legal Eagle’s and Defendants’ cross motions for partial

summary judgment on the counts related to the requests for expedited processing. Additionally,

Legal Eagle filed a motion to strike Defendants’ cross motion for partial summary judgment,

arguing that Defendants failed to adhere to proper motions practice procedure.

For the reasons discussed below, the Court will grant RAISMD’s motion to dismiss

pursuant to Armstrong v. Exec. Office of the President, 90 F.3d 553 (D.C. Cir. 1996). As a

subcomponent of the NSC, which is not subject to FOIA, the Court finds that RAISMD is not

subject to FOIA. With respect to the motions for partial summary judgment, the Court agrees

with Defendants that based on the records before the agencies, the requests for expedited

processing were properly denied. Finally, the Court finds nothing procedurally improper with

Defendants’ cross motion for partial summary judgment, and therefore will deny Legal Eagle’s

motion to strike.

II. BACKGROUND

As alleged in the Amended Complaint, Legal Eagle runs a “YouTube channel focused on

legal issues . . . with more than one million subscribers, ten million monthly views, and 100

million total video views.” Am. Compl. ¶ 3, ECF No. 5. The channel “features a recurring

segment entitled ‘Real Law Review,’ in which the host explains the legal issues behind major

stories in the news . . . for a general audience.” Id. ¶ 37. The company seeks records related to

the prepublication review of a manuscript written by Former National Security Advisor John

Bolton. Id. ¶ 38.

Any person who possesses a security clearance must sign a Non-Disclosure Agreement

that includes an agreement to submit any manuscript related to his or her national security

2 employment for prepublication review prior to disclosing it to any third party. Id. ¶ 15. The

review process, generally handled by the agency that sponsored the security clearance, allows the

government to deny an author permission to publish both classified and unclassified information

depending on the circumstances. See id. ¶ 21. In late 2019, RAISMD conducted a

prepublication review of Mr. Bolton’s book, The Room Where It Happened, and determined that

it contained classified information. See id. ¶¶ 24–36. In June 2020, despite the ongoing

prepublication review and determination that the manuscript contained classified information,

Mr. Bolton had printed and shipped the book to distributors across the country. Id. ¶ 33. This

led to the government seeking a temporary restraining order to prevent the book’s distribution.

Id. ¶ 35. Although Judge Lamberth denied the government’s motion, he stated that “the Court is

persuaded that Defendant Bolton likely jeopardized national security by disclosing classified

information in violation of his nondisclosure agreement obligations.” Id. ¶ 36 (quoting United

States v. Bolton, 468 F. Supp. 3d 1, 5 (D.D.C. 2020)).

Legal Eagle submitted a series of FOIA requests to Defendants seeking records and

information regarding Mr. Bolton’s book, the prepublication review process, and the information

the government prohibited, or attempted to prohibit, Mr. Bolton from publishing. See generally

Pl.’s Mot. Partial Summ. J. Ex. A, ECF No. 13-1. Alongside the requests for records, Legal

Eagle submitted requests for expedited processing. See generally id. The requests for expedited

processing explained that Legal Eagle runs a YouTube channel focused on informing the public

about legal issues and that the requested information concerned operations or activity of the

government. See id. In addition, the requests for expedited processing included the following

statement:

[B]ecuase of the issues surrounding [Mr. Bolton’s] manuscript and the Government’s efforts to prohibit [Mr.] Bolton from providing the requested

3 information—either in his book or in Congressional testimony—this request satisfies the compelling need standard for expedited processing, since it is made by a person primarily engaged in disseminating information to inform the public about Government activity involving topics of breaking news.

Id. 1 Two offices—the DOJ National Security Division and the Office of Legal Counsel

(“OLC”)—agreed to expedite Legal Eagle’s FOIA requests. Pl.’s Mem. of P. & A. Supp. Cross

Mot. Partial Summ. J. (“Pl.’s Mem.”) at 1–2, ECF No. 13. Five offices denied Legal Eagle’s

requests to expedite and RAISMD did not decide the matter with respect to three requests. Id. at

2. Counts 2, 4, 6, 8, 12, 14, 16, and 18 of the Amended Complaint charge Defendants with

improperly denying, or constructively denying in RAISMD’s case, Legal Eagle’s requests to

expedite processing of its FOIA requests. See Am. Compl. ¶¶ 50–53, 60–63, 73–76, 87–90,

120–23, 131–34, 141–44, 152–57.

Pending before the Court are several motions. Defendants filed a partial motion to

dismiss arguing that RAISMD is not subject to FOIA because the NSC, of which it is a part, is

not subject to FOIA under D.C. Circuit precedent. See Defs.’ Partial Mot. Dismiss, ECF No. 7.

Legal Eagle filed a motion for partial summary judgment on the counts related to its requests to

expedite processing. See Pl.’s Mem. In response, Defendants filed a cross motion for partial

summary judgment of their own on the requests to expedite counts. See Defs.’ Cross Mot.

Partial Summ. J. (“Defs.’ Partial MSJ”), ECF No. 21. Finally, because Legal Eagle argues that

Defendants’ cross motion for summary judgment was improperly filed, it filed a motion to strike

Defendants’ cross motion and the reply in support of that motion. See Pl.’s Mot. Strike, ECF No.

27.

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