National Association of Minority Veterans v. United States Department of Veterans Affairs

CourtDistrict Court, District of Columbia
DecidedNovember 18, 2022
DocketCivil Action No. 2021-1298
StatusPublished

This text of National Association of Minority Veterans v. United States Department of Veterans Affairs (National Association of Minority Veterans v. United States Department of Veterans Affairs) 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.

Bluebook
National Association of Minority Veterans v. United States Department of Veterans Affairs, (D.D.C. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

NATIONAL ASSOCIATION OF : MINORITY VETERANS, : : Plaintiff, : Civil Action No.: 21-1298 (RC) : v. : Re Document Nos.: 18, 21 : UNITED STATES DEPARTMENT OF : VETERANS AFFAIRS, : : Defendant. :

MEMORANDUM OPINION

DENYING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT; GRANTING IN PART AND DENYING IN PART PLAINTIFF’S CROSS-MOTION FOR SUMMARY JUDGMENT; OVERRULING PLAINTIFF’S EVIDENTIARY OBJECTIONS AS MOOT

I. INTRODUCTION

Plaintiff National Association of Minority Veterans (the “Association”) brings this action

under the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, against the United States

Department of Veterans Affairs (the “VA”). The Association, which represents the interests of

minority veterans, seeks to compel disclosure of records that it claims were unlawfully withheld

pertaining to the policies and practices of the VA Police Force (“VPD”) at Veterans Health

Administration (“VHA”) facilities. The VA’s motion for summary judgment and the

Association’s cross-motion for summary judgment are ripe for review. For the reasons stated

below, the Court denies the VA’s motion and grants in part and denies in part the Association’s

cross-motion. The Association also submitted a set of evidentiary objections to the affidavit

attached to the VA’s motion, which the Court overrules as moot. II. FACTUAL BACKGROUND

The heart of the parties’ disagreement is over whether an email from the Association to

the VA specifying the particular records sought as part of discussions between the parties after

this suit was filed in fact constituted a second FOIA request, such that the VA’s production in

response to the email may not be challenged pursuant to the original FOIA request.

A. The Original Request

The Association filed the original FOIA request (the “Original Request”) on November

11, 2020. Compl. ¶ 7, ECF No. 1; Answer ¶ 7, ECF No. 7; Ex. A to Compl. (“Original

Request”). The Original Request had several subsections, each containing numerous separate

record requests. Original Request at 3. On December 23, 2020, the VA Office of Inspector

General (“OIG”) sent a letter to the Association stating that the VA received the Original

Request and assigned portions of it to OIG, which assigned it a tracking number. Ex. B to

Compl. at 1. The letter advised that “this project and all information gathered were legally

destroyed on 1/18/2019, since they have reached the end of their records retention period,” and

therefore that OIG “must provide a ‘no records’ found response.” Id.

On January 25, 2021, the Association appealed OIG’s response. Ex. C to Compl. The

appeal letter stated that the Association believed that OIG’s “‘no records’ found response was in

error,” and clarified the two parts of the Original Request to which it believed OIG would have

responsive records: (1) Part II.A.3, which sought

Any and all Records concerning the behavioral record flag policies and procedures utilized by the VAPD and VHA staff including, but not limited to ... VA and VHA definitions and applications of “disruptive behavior” . . . including but not limited to definitions recommended by the Office of the Inspector General (OIG) Management of Disruptive Patient Behavior at VA Medical Facilities (2013).6

2 6 See, e.g., Department of Veterans Affairs, Office of the Inspector General, Management of Disruptive Patient Behavior at VA Medical Facilities (2013).;

and (2) Part II.D, which sought

Any and all Records concerning notice, discussion of, and compliance with Department of Veterans Affairs Office of Inspector General guidelines and recommendations issued between 2014 and 2020, including, but not limited to: 1. Implementation of recommended designated manager of the records management systems for the VAPF;7 and 2. Findings of the working group established to evaluate whether the Report Exec system meets the needs of VAPF, including strategies to implement this system or its replacement;8 and 3. Development and implementation of a plan for resolving issues with the police records management system.9 7 See, e.g., Department of Veterans Affairs, Office of the Inspector General, VA Police Management System Needs Improvement (2020). 8 Id. 9 Id.

Id. at 1; Original Request at 3.

The appeal letter stated that, “[b]ased on [the VA’s] December 23 response, we

recognize that the information gathered for the 2013 report was legally destroyed” and therefore

that the Association “no longer seek[s] that data.” Ex. C to Compl. at 1. However, the appeal

letter continued, “[i]nstead, and consistent with our November 11 FOIA request, we would like

to see any data that examines behavioral record flag policies from relevant OIG reports

including” three specific reports—a January 30, 2018 report, a December 13, 2018 report, and a

June 17, 2020 report. 1 Id. The appeal letter explained that the Association’s “request in Part II

D was not limited to the 2013 report,” and accordingly that it believed that responsive “records

should exist.” Id. at 2.

1 The June 17, 2020 report is the same as that listed in footnote 7 of the original request.

3 Three days later, on January 28, 2021, OIG sent the Association a response letter denying

the appeal. Ex. D. to Compl. at 2. The response letter restated the Association’s request for

“Department of Veterans Affairs Office of Inspector General guidelines and recommendations

issued between 2014 and 2020,” and noted that the request specifically mentioned the 2013 and

2020 reports. Id. at 1. It repeated OIG’s finding that records related to the 2013 report were

legally destroyed, but made no mention of the other reports before concluding that “the search by

the FOIA staff was adequate and reasonable.” Id. at 2. The Association filed this action on May

11, 2021 asking the court to declare that the VA failed to comply with FOIA and order the VA to

produce responsive records. See Compl.

B. The Negotiated Request

It is the events that occurred after the Association initiated this suit that are centrally

relevant here. On August 8, 2021, the VA filed a status report with the Court stating that

“[s]ince the filing of the lawsuit, the parties have begun the process of negotiating over the scope

of Plaintiff’s FOIA Request” and that “[o]ver the next few weeks, Plaintiff and Defendant plan to

confer in good faith over the scope of Plaintiff’s FOIA Request and update the Court.”

Defendant’s Status Report at 2, ECF No. 8. On October 5, 2021, the parties filed a joint status

report explaining that, since the previous status report was filed, “the parties have continued the

process of negotiating over the scope of Plaintiff’s FOIA Request.” October 5, 2021 Joint Status

Report at 1, ECF No. 12. Most importantly for present purposes, it stated that

[o]n August 10, 2021, counsel for the parties had a lengthy meet and confer to discuss the breadth of Plaintiff’s FOIA request and to ask Plaintiff to identify which OIG reports and underlying data Plaintiff was interested in as a way of reaching an agreement regarding the scope of Plaintiff’s FOIA request. Plaintiff provided Defendant, through counsel, with guidance regarding three specific reports and the data from those three reports on August 23, 2021.

Id. at 1–2.

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