Leopold v. Central Intelligence Agency

CourtDistrict Court, District of Columbia
DecidedMarch 30, 2026
DocketCivil Action No. 2022-0453
StatusPublished

This text of Leopold v. Central Intelligence Agency (Leopold 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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Leopold v. Central Intelligence Agency, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JASON LEOPOLD, et al.,

Plaintiffs,

v. No. 22-cv-453 (DLF)

CENTRAL INTELLIGENCE AGENCY,

Defendant.

MEMORANDUM OPINION

Jason Leopold and his now-former employer, Buzzfeed Inc. (Buzzfeed), bring this action

against the Central Intelligence Agency (CIA) under the Freedom of Information Act (FOIA), 5

U.S.C. § 552, et seq. See Compl., Dkt. 1. Leopold and Buzzfeed claim that the CIA violated FOIA

by withholding information pertaining to the CIA Inspector General’s investigations into sustained

or alleged misconduct from 2020 and 2021. Before the Court is the CIA’s Motion for Summary

Judgment, Dkt. 30, and the plaintiffs’ Cross-Motion for Summary Judgment, Dkt. 33. For the

reasons that follow, the Court will grant in part and deny in part both motions.

I. BACKGROUND

Jason Leopold, an investigative reporter at Buzzfeed, sought “to report on how the CIA

investigates alleged misconduct by its personnel.” Def.’s Resp. Pls.’ Stmt. Material Facts ¶ 1, Dkt.

39-2. In December 2021, Leopold submitted a FOIA request to the CIA’s Office of the Inspector

General (OIG) for copies of the concluding documents for investigations that ended in calendar

years 2020 and 2021 “concerning misconduct, actual or alleged” to effectuate his reporting. Pls.’

Resp. Def.’s Stmt. Material Facts ¶ 1, Dkt. 33-4. After the CIA failed to issue a timely determination, the plaintiffs initiated the instant

lawsuit in February 2022. Def.’s Resp. Pls.’ Stmt. Material Facts ¶ 1 (second paragraph labeled

“1”). During litigation, the CIA processed 67 reports, releasing 65 in part and withholding two in

full. Id. at ¶ 2. The plaintiffs do not contest the adequacy of the CIA’s search in responding to

their FOIA request, id. at ¶ 5, but they challenge its withholdings. Initially, the CIA withheld

information under FOIA Exemptions 1, 3, 6, 7(C), 7(D), and 7(E), Pls.’ Resp. Def.’s Stmt. Material

Facts ¶ 4. During the course of briefing on the pending motions, the CIA has since narrowed the

scope of its withholdings.

At the outset, the CIA withheld certain information in 56 reports under Exemption 1, Def.’s

Mem. Support Mot. Summ. J. 4, Dkt. 30-1, which protects classified information and information

“to be kept secret in the interest of national defense or foreign policy,” 5 U.S.C. § 552(b)(1). Of

particular concern in litigation was the CIA’s withholding under Exemption 1 of certain

information in Document Number C06948222, which, according to the CIA’s Vaughn Index,

“summariz[ed] investigation and findings regarding an alleged violation of the Hatch Act.” Decl.

Mary C. Williams Ex. E (Vaughn Index), at 25, Dkt. 31-5. The alleged violation involved a CIA

employee “who self-reported a potential violation of the Hatch Act” by seeking out “‘phone

banking’ activity to encourage voter turnout.” Def.’s Resp. Pls.’ Stmt. Material Facts ¶ 11. The

CIA applied Exemption 1 to withhold the name of a CIA employee, which the plaintiffs contested,

Pls.’ Mem. Support Cross-Mot. Summ J. 10–11, and which the CIA later retracted, Supp. Decl.

Mary C. Williams ¶ 6, Dkt. 38-1.

In Document Number C06948222 and the other 66 reports, the CIA withheld certain

information under Exemption 3. Def.’s Mem. Support Mot. Summ. J. 8 n.3. Exemption 3

incorporates into FOIA “the protections of other shield statutes” that specifically allow for

2 nondisclosure of certain information. ACLU v. U.S. Dep’t of Def., 628 F.3d 612, 618 (D.C. Cir.

2011). The CIA relied on two statutes for its application of Exemption 3: the CIA Act of 1949, 50

U.S.C. § 3507 et seq., and the National Security Act of 1947, 50 U.S.C. § 3024 et seq. Def.’s

Mem. Support Mot. Summ. J. 8. Relying on the CIA Act, the CIA withheld information in all 67

reports, id. at 8 n.3, and 65 reports faced withholdings under the National Security Act, id. at 9 n.4.

As it pertains to Document Number C06948222, the CIA elected to initially rely in part on

Exemption 3 in conjunction with the CIA Act to withhold the name of the CIA employee, before

later relying only on Exemption 3. Supp. Decl. Mary C. Williams ¶¶ 6, 8–9. The CIA also relied

in part on Exemption 3 in conjunction with the National Security Act to withhold classification

and control markings from the document’s classification block. Id. at ¶ 8.

Under Exemption 6, the CIA withheld certain information from all 67 reports. See

generally Vaughn Index. Exemption 6 permits the CIA to withhold information about individuals

that, if disclosed, “would constitute a clearly unwarranted invasion of personal privacy.” 5 U.S.C.

§ 552(b)(6). The plaintiffs do not contest the CIA’s withholdings under Exemption 6. Pls.’ Resp.

Def.’s Stmt. Material Facts ¶ 5.

The CIA also relied on Exemption 7, which generally protects from disclosure information

collected for “law enforcement purposes,” 5 U.S.C. § 552(b)(7), to withhold certain information

from every responsive report. In particular, the CIA applied Exemption 7(C), which protects

personal information in law enforcement records, to information in all 67 reports. See generally

Vaughn Index. The plaintiffs do not contest those withholdings. Pls.’ Resp. Def.’s Stmt. Material

Facts ¶ 5. The CIA’s Vaughn Index indicates that four reports initially included information

withheld by CIA under Exemption 7(D), which protects law enforcement records that could

3 reasonably be expected to disclose the identity of a confidential source. 1 See Vaughn Index 3–4,

6, 38. The CIA generally withheld via Exemption 7(D) information containing the names and

certain statements of interviewees, all of which was concurrently withheld under Exemption 7(C).

Def.’s Mem. Support Mot. Summ. J. 10, 11 n.6. Furthermore, the CIA redacted information from

54 reports under Exemption 7(E). Id. at 11. The plaintiffs contest the CIA’s articulation of

foreseeable harm under Exemption 7(E) in litigation, but the CIA has withdrawn its application to

certain information in 26 documents. Supp. Decl. Mary C. Williams ¶ 17. Withholdings under

Exemption 7(E) were accompanied by another exemption in all but two documents, according to

the CIA. 2 In litigation, the plaintiffs challenge the CIA’s general application of Exemption 7 to

nine documents. Pls.’ Mem. Support Cross-Mot. Summ. J. 6–7, Dkt. 33-1. The CIA has

withdrawn its application of Exemption 7 to four documents, 3 but has maintained its Exemption 7

withholdings for the other five. 4 Supp. Decl. Mary C. Williams ¶ 11.

Before the Court are the CIA’s Motion for Summary Judgment and the plaintiffs’ Cross-

Motion for Summary Judgment. The parties, as mentioned, have narrowed the scope of their

dispute through the course of this litigation. Four issues remain: (1) whether there is a statutory

basis for certain of the CIA’s withholdings under Exemption 3; (2) whether the CIA “compiled for

1 The reports are Document Numbers C06947930, C06947947, C06947957, and C06948246. See Vaughn Index 3–4, 6, 38.

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