ACLU of Northern California v. FBI

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For generalized records, such as training manuals and guidelines, the government's burden under Exemption 7 of the Freedom of Information Act (FOIA), 5 U.S.C. 552(b)(7), of demonstrating that withheld materials were "complied for law enforcement purposes" can be satisfied without linking the documents to the enforcement of a particular statute. The government need only show a "rational nexus" between enforcement of federal law and a withheld document to invoke Exemption 7. In this case, the Ninth Circuit vacated the district court's grant of summary judgment for plaintiffs in an action seeking information from the FBI under FOIA. The panel remanded for further proceedings. View "ACLU of Northern California v. FBI" on Justia Law