Thursday, June 22, 2017

Case of the Day: Katsiaficas v. U.S. CIA, 2017 U.S. Dist. LEXIS 75392 (D. Mass. May 17, 2017)


Plaintiff is a professor who filed a Freedom of Information Act (FOIA) request to the Central Intelligence Agency for documents regarding former South Korean dictator Park Chung-hee. After the CIA produced a small number of documents, plaintiff further challenged the adequecy of CIA's production. CIA filed for summary judgment.

Court granted the summary judgment, finding that CIA made a good faith effort to conduct a search for the requested records using methods which can be reasonably expected to produce the information requested. The court also found that CIA appropriately withheld documents designated specifically by executive orders.


The wide variety of cases that have to do with Asia never fails to surprise me. Initially I expected mostly trade disputes and perhaps product liability suits, but random gems like this makes my day. FOIA summary judgment standard! I bet not too many attorneys are familiar with that one.

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