Columbia Legal Services v. U.S. Department of Labor

We represent Columbia Legal Services (CLS) in a Freedom of Information Act (FOIA) case against the U.S. Department of Labor (DOL). State workforce agencies conduct wage surveys and report the results to DOL using Form ETA-232 and corresponding attachments. CLS submitted a FOIA request to DOL seeking copies of such records submitted to DOL by the Washington State Employment Security Department, and specifically requested the attachments in Excel format. DOL produced the documents in PDF but refused to produce them in Excel, even though FOIA requires an agency to provide a requested record in the format requested if the record is readily reproducible by the agency in that format. We filed suit in the U.S. District Court for the District of Columbia to compel DOL to produce the records in Excel.