During Eleanor Roosevelt’s life, the FBI maintained an extensive file on her. Plaintiff Christopher Brick is the Project Director and Editor for the Eleanor Roosevelt Papers Project, a George Washington University research center with the mission of making the vast record of Eleanor Roosevelt’s written, spoken, and audio-visual legacy accessible to the general public. To that end, Mr. Brick submitted a FOIA request to the FBI for certain documents in the Eleanor Roosevelt File. The FBI heavily redacted some of the documents it released in response to the FOIA request. Public Citizen represents Mr. Brick in this action seeking to compel the government to release the documents in full.
Both the government and Public Citizen filed motions for summary judgment. In November 2017, the district court accepted Public Citizen’s argument that the government had not justified its redaction of the records, but that the government would have another opportunity to do so through submission of the records for in camera review, filing of a supplemental declaration explaining the basis for redacting them, and further briefing. In response to the court’s ruling both the government and Public Citizen filed renewed motions for summary judgment, with the government placing all of its arguments in a sealed declaration. After review of the government’s secret declaration and the documents themselves, the court ultimately concluded that revealing the redacted material would reveal intelligence sources and methods, as well as law enforcement methods whose revelation would create a risk of circumvention of the law. The court therefore upheld the government’s withholding of the redacted materials.