. for L. & Just. v. DHS, 573 F.Supp.3d 78, 81-82 (D.D.C. 2021) (“ACLJ') (cleaned up); see also 29 C.F.R. § 70.19(c) (“Requesters must describe the . . . records sought in sufficient detail to enable Department personnel to locate them with a reasonable amount of effort.”).
"[A FOIA] request ‘reasonably describes’ agency records when it ‘would be sufficient to enable a professional employee of the agency who was familiar with the subject area of the request to locate the record with a reasonable amount of effort.’ " Am. Ctr. for L. & Just. v. U.S. Dep't of Homeland Sec., Case No. 1:21-cv-01364 (TNM), 573 F.Supp.3d 78, 81 (D.D.C. Nov. 10, 2021) (alteration omitted) (quoting Truitt v. Dep't of State, 897 F.2d 540, 545 n.36 (D.C. Cir. 1990) ). "The linchpin inquiry is whether ‘the agency is able to determine precisely what records are being requested,’ " Dale v. IRS, 238 F. Supp. 2d 99, 104 (D.D.C. 2002) (quoting Tax Analysts v. IRS, 117 F.3d 607, 610 (D.C. Cir. 1997) )—"[b]road, sweeping requests lacking specificity are not sufficient," i
Indeed, President Biden moved swiftly to reverse or modify several of President Trump's immigration initiatives and policies. See Am. Ctr. for Lawand Just. v. DHS (ACLJ), 573 F. Supp. 3d 78, 80 (D.D.C. 2021) (noting these changes).
See Nat'l Sec. Couns., 969 F.3d at 409-10 (finding request for “all [CIA] records pertaining to the IBM supercomputer named Watson” unreasonably described) (internal quotation marks omitted); Am. Ctr. for L. & Just. v. DHS, 573 F.Supp.3d 78, 85 (D.D.C. 2021) (same when request sought “documents ‘referencing or regarding in any way' eight topics”); MacLeod, 2017 WL 4220398, at *12 (same when request sought documents with “information relating to” certain topics); Hainey v. U.S. Dep't of the Interior, 925 F.Supp.2d 34, 43 (D.D.C. 2013) (same when request sought documents “relating to vacancy announcements” and “hiring reform”) (emphasis removed); Dale, 238 F.Supp.2d at 104 (same when request sought “any and all documents, including but not limited to files, that refer or relate in any way to Billy Ray Dale”).
. See, e.g., Am. Ctr. for L. & Just. v. U.S. Dep't of Homeland Sec., 573 F.Supp.3d 78, 85 (D.D.C. 2021); Shapiro v. CIA, 170 F.Supp.3d 147, 155 (D.D.C. 2016). After all, “as many a curbstone philosopher has observed, everything is related to everything else.”
A FOIA request “‘reasonably describes' agency records when it ‘would be sufficient [to enable] a professional employee of the agency who was familiar with the subject area of the request to locate the record with a reasonable amount of effort.'” Am. Ctr. for Liberty & Just. v. U.S. Dep't of Homeland Sec. (“ACLJ”), 573 F.Supp.3d 78, 81 (D.D.C. 2021) (alteration in original) (quoting Truitt v. Dep't of State, 897 F.2d 540, 545 n.36 (D.C. Cir. 1990)).
But Request No. 6 must be read “as drafted.” American Ctr. for Law and Justice v. DHS, 573 F.Supp.3d 78, 86 (D.D.C. 2021). The plain language of Request No. 6 is not limited total data, and if Plaintiffs only sought such aggregate information, they could have made this request explicit.
(quoting Kowalczyk v. Dep't of Just., 73 F.3d 386, 388 (D.C. Cir. 1996)); see also Am. Ctr. for L. & Just. v. U.S. Dep't of Homeland Sec., 573 F.Supp.3d 78, 81 (D.D.C. 2021) (“[A] request ‘reasonably describes' agency records when it ‘would be sufficient [to enable] a professional employee of the agency who was familiar with the subject area of the request to locate the record with a reasonable amount of effort.'” (quoting Truitt, 897 F.2d at 545 n.36)).
for L. & Just. v. DHS, 573 F.Supp.3d 78, 81 (D.D.C. 2021) (quotation omitted).
Am. Ctr. for L. & Just. v. U.S. Dep't of Homeland Sec. (ACLJ), No. 21-cv-01364, 2021 WL 5231939, at *5 (D.D.C. Nov. 10, 2021).