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Reynolds v. United States
Citation: 350 F. App'x 474Docket: No. 08-0926-cv
Court: Court of Appeals for the Second Circuit; September 17, 2009; Federal Appellate Court
James J. Reynolds, proceeding pro se, appeals a judgment from the United States District Court for the Southern District of New York, which granted summary judgment to the United States regarding his Freedom of Information Act (FOIA) claims. The appellate court reviews this de novo, focusing on whether the district court correctly determined the absence of genuine material issues and the entitlement of the moving party to judgment as a matter of law. To succeed in a FOIA summary judgment motion, the agency must demonstrate that its search was adequate and that any withheld documents are exempt under FOIA. Affidavits from agencies that detail their thorough search and provide reasonable explanations for withheld documents are given a presumption of good faith, which cannot be countered by speculative claims about the existence of other documents. In this case, Reynolds failed to present evidence contradicting the agency affidavits, which confirmed that relevant documents were either not found or produced. Although he argued that ambiguities in the Federal Bureau of Investigation (FBI) and National Archives and Records Administration (NARA) declarations indicated withholding, these agencies clearly stated no relevant documents were uncovered. Reynolds also claimed a Department of Education (DOE) employee assured him a written record of his inquiry existed, but he provided no evidence to support this claim, which was deemed insufficient to overcome the presumption of good faith. Reynolds contended that NARA did not adequately search for records related to his request, but NARA explained that it had already searched its computerized index without finding any reference to him. The court noted that NARA was only required to conduct a search reasonably calculated to find relevant documents, which it did. The appellate court found Reynolds’s remaining arguments meritless and affirmed the district court's judgment. Additionally, Reynolds’s motion to reinstate his claims against the City of New York was denied.