Campo v. DOJ, No. 19-00905, 2020 WL 3966874 (W.D. Mo. July 13, 2020) (Smith, J.)

Campo v. DOJ, No. 19-00905, 2020 WL 3966874 (W.D. Mo. July 13, 2020) (Smith, J.)

Re:  Request for emails sent by third party

Disposition:  Granting defendant's motion for summary judgment; denying plaintiff's motion for judgment on the pleadings

• Exemptions 6 & 7(C):  The court holds that "[i]n these particular circumstances, DOJ's decision not to perform a search for responsive documents unless and until it received a death certificate, privacy waiver, or showing that the public interest in disclosure outweighs the third party's privacy interest is lawful under Exemption 7(C)."  The court finds that "[plaintiff] did not provide EOUSA with an authorization signed by [the third party]."  "And [plaintiff] did not establish there was any public interest in disclosure that outweighed [the third party's] strong privacy interests."
   
• Exemption 4:  The court notes that "this Court [as well as the Court of Appeals for the D.C. Circuit] has [previously] determined [that one] email is exempt from disclosure pursuant to Exemption 4."