Rhodes v. FBI, No. 16-1111, 2018 WL 2994397 (D.D.C. June 14, 2018) (McFadden, J.)

Rhodes v. FBI, No. 16-1111, 2018 WL 2994397 (D.D.C. June 14, 2018) (McFadden, J.)

Re:  Request for records about the requester

Disposition:  Granting defendant's motion for summary judgment

• Exemption 7(E), Glomar: The court upholds the FBI's Glomar response regarding watch-list information.  Because "any potential 'watchlist records responsive to Plaintiff . . . would relate to investigative matters that are part of the FBI's primary law enforcement mission[,]'" the court holds that "[t]he threshold law enforcement requirement of Exemption 7(E) is without question satisfied."  The court cites to previous cases in holding "that anything other than a 'neither confirm nor deny' response would tend to disclose at the very least ‘guidelines for law enforcement investigations or prosecutions’ and that such disclosure 'could reasonably be expected to risk circumvention of the law.'"