Archibald v. DOJ, No. 13-5190, 2014 U.S. App. LEXIS 1787 (D.C. Cir. Jan. 28, 2014) (per curiam)

Archibald v. DOJ, No. 13-5190, 2014 U.S. App. LEXIS 1787 (D.C. Cir. Jan. 28, 2014) (per curiam)

Re:  Request for records concerning President Obama's status as natural born or naturalized United States citizen

Disposition:  Denying motion for summary reversal; granting motion for summary affirmance

• Exemption 7(C):  The court holds that "[t]he district court correctly concluded the records sought by appellant were records 'compiled for law enforcement purposes,' and properly sustained the government's withholding of those records under Exemption 7(C)."
   
• Litigation Considerations, Vaughn Index/Declaration:  The court finds that "the district court appropriately determined the Federal Bureau of Investigation's sworn declaration was adequate to substantiate its exemption claim without producing a Vaughn index."
   
• Litigation Considerations, In Camera Inspection:  The court holds that "having determined the agency had met its burden by means of the declaration, the district court did not abuse its discretion in declining to conduct in camera review of the records."