Evans v. Bureau of Prisons, No. 18-5068 (D.C. Cir. 2020)
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Plaintiff filed suit under the Freedom of Information Act (FOIA) seeking to compel the release of records related to an incident in which plaintiff was stabbed from behind with a screwdriver in prison.
The DC Circuit affirmed the district court's grant of summary judgment insofar as it pertains to the Bureau's response to plaintiff's request for records related to the screwdriver. In this case, nothing in the record refutes the Bureau's repeated assertions that it knows nothing about the screwdriver and has no records responsive to plaintiff's demands. The court vacated and remanded the judgment to the district court in regard to the Bureau's withholding of surveillance footage under Exemptions (b)(7)(C) and (b)(7)(E), holding that the agency's declaration was too unspecific on its own to establish that withholding the footage was justified.
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