Maynard v. Agency

Case Date: 02/12/1993
Court: United States Court of Appeals
Docket No: 91-1334


F e b r u a r y 1 1 , 1 9 9 3
UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT
____________________

No. 91-1334

BEATRICE MAYNARD,

Plaintiff, Appellee,

v.

CENTRAL INTELLIGENCE AGENCY,

Defendant, Appellant.

____________________

No. 92-1615

BEATRICE MAYNARD,

Plaintiff, Appellant,

v.

CENTRAL INTELLIGENCE AGENCY, ET AL.,

Defendants, Appellees.

____________________

ERRATA SHEET

The opinion of this Court issued on February 4, 1993, is
amended as follows:

On page 3, line 7, delete "lower court's".

On page 3, after "it." on line 3 of second paragraph, add
footnote 3 as follows: For the record, that order was not issued
by the Judge from whose final orders the appeal is taken."

On page 34, line 17, replace "appropriate" with
"inappropriate".



February 11, 1993 UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT
____________________

No. 91-1334

BEATRICE MAYNARD,

Plaintiff, Appellee,

v.

CENTRAL INTELLIGENCE AGENCY,

Defendant, Appellant.

____________________

No. 92-1615

BEATRICE MAYNARD,

Plaintiff, Appellant,

v.

CENTRAL INTELLIGENCE AGENCY, ET AL.,

Defendants, Appellees.

____________________

ERRATA SHEET

The opinion of this Court issued on February 4, 1993, is
amended as follows:

On page 47, last line, replace "Costs to appellees." with
___________________
"Costs to appellees in No. 92-1615 and to appellant in No. 91-
_____________________________________________________________
1334."
____




February 5, 1993 UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT
____________________

No. 91-1334
BEATRICE MAYNARD,

Plaintiff, Appellee,
v.

CENTRAL INTELLIGENCE AGENCY,
Defendant, Appellant.

____________________
No. 92-1615

BEATRICE MAYNARD,
Plaintiff, Appellant,

v.
CENTRAL INTELLIGENCE AGENCY, ET AL.,

Defendants, Appellees.
____________________

APPEALS FROM THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MAINE

[Hon. D. Brock Hornby, U.S. District Judge]
___________________
____________________

Before
Breyer, Chief Judge,
___________

Campbell, Senior Circuit Judge,
____________________
and Torruella, Circuit Judge.
_____________

____________________

Steven J. Lyman with whom Law Office of Carl D. McCue was on
_______________ ___________________________
brief for plaintiff.
John P. Schnitker, Appellate Staff, Civil Division, Department of
_________________
Justice, with whom Stuart M. Gerson, Assistant Attorney General,
________________
Richard S. Cohen, United States Attorney, and Leonard Schaitman,
________________ _________________
Appellate Staff, Civil Division, Department of Justice, were on briefs
for defendants.
____________________

February 4, 1993
____________________


CAMPBELL, Senior Circuit Judge. Plaintiff Beatrice
____________________

Maynard brought this action in the district court to compel

disclosure under the Freedom of Information Act ("FOIA"), 5

U.S.C. 552, of certain government documents and parts of

documents pertaining to the disappearance of her former

husband, Robert Thompson, during a flight over Cuba in

December of 1961. Maynard had sought information about this

from various agencies, including the Central Intelligence

Agency ("CIA"), the Federal Bureau of Investigation ("FBI"),

the Defense Intelligence Agency ("DIA"), the State

Department, the Immigration and Naturalization Service

("INS"), the United States Customs Service ("Customs

Service"), the Federal Aviation Administration ("FAA"), the

National Personnel Records Center ("NPRC"), and the Navy

Department.1 While certain records and other materials were

provided to her, Maynard felt that she was entitled to more,

and so brought this suit.

After reviewing several documents in camera, the
__ ______

district court ordered disclosure of two items of information

one name and one paragraph that the government had

expressly redacted from materials it had furnished to

plaintiff. The CIA appeals from the court's direction to

reveal the paragraph, arguing that the paragraph was properly


____________________

1. The district court granted the parties' stipulated
dismissal of the FAA, the NPRC, and the Navy in February
1990.

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withheld under FOIA's Exemptions 1 and 3, 5 U.S.C.

552(b)(1), (3).2 In all other respects, the district court

granted summary judgment in favor of the defendant agencies,

denying plaintiff's requests for further information, for

further document searches, and for attorney's fees.

Plaintiff now appeals from these judgments.

Finding that Exemptions 1 and 3 authorize the CIA's

withholding of the redacted paragraph, we reverse the order

requiring the CIA to disclose it3. We affirm the district

court's grant of summary judgment for the defendant agencies.

I.
I.

1. The CIA's Appeal
________________

On January 22, 1987, plaintiff submitted FOIA

requests to the defendant agencies, seeking any information


____________________

2. FOIA Exemption 1 provides that the FOIA's disclosure
requirements do not apply to matters that are "(1)(A)
specifically authorized under criteria established by an
Executive order to be kept secret in the interest of national
defense or foreign policy and (B) are in fact properly
classified pursuant to such Executive order." 5 U.S.C.
552(b)(1). The information at issue here was classified
pursuant to Executive Order 12356, 47 Fed. Reg. 14874 (1982).
FOIA Exemption 3 pertains to matters that are exempted
from disclosure by a statute that either "(A) requires that
the matters be withheld from the public in such a manner as
to leave no discretion on the issue, or (B) establishes
particular criteria for withholding or refers to particular
types of matters to be withheld." 5 U.S.C. 552(b)(3). The
exempting statute here is 50 U.S.C. 403(d)(3), which
provides that "the Director of Central Intelligence shall be
responsible for protecting intelligence sources and methods
from unauthorized disclosure."

3. For the record, that order was not issued by the Judge
from whose final orders the appeal is taken.

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they might have concerning her former husband, Robert

Thompson. She said he disappeared along with Robert Swanner

on a flight over Cuba, in December of 1961. Thompson

apparently was involved in the distribution of anti-Castro

leaflets; plaintiff believed him to have worked for the CIA.

Among documents produced by the FBI in response to

plaintiff's requests was a redacted memo dated December 22,

1961. The FBI informed plaintiff that the excised

information had originated with the CIA and was being

withheld under FOIA Exemptions 1 and 3 at the CIA's request.

Plaintiff brought this action in the district court in

February 1988, seeking more complete disclosure, including

disclosure of the withheld paragraph.

After the agency defendants moved for summary

judgment, the district court in March of 1990 ordered the

government to submit for the court's in camera inspection all
__ ______

withheld and redacted documents in their complete form. The

government did so on May 1, 1990. Among the documents

submitted were thirty-two pages the FBI had located in its

search for documents responsive to plaintiff's FOIA

request.4 This material included the redacted memo of

____________________

4. The State Department also submitted for in camera review
__ ______
a document on which the State Department had redacted certain
identifying information, such as the names of individuals,
for personal privacy concerns pursuant to FOIA Exemption 6.

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December 22, 1961 that has since become the subject of the

CIA's appeal.

To help explain its position, the CIA submitted to

the district court the public declaration of Katherine M.

Stricker, an Information Review Officer for the CIA's

Directorate of Operations. With respect to Exemption 1,

which exempts national security information classified

pursuant to an Executive Order, Stricker explained that she

had personally reviewed the classification determinations

under the standards of Executive Order 12356. Based on that

review, Stricker determined that the withheld information

would "reveal the identity of an intelligence source or

disclose an intelligence method," the unauthorized disclosure

of which, "either by itself or in the context of other

information, reasonably could be expected to cause damage to

the national security." See Executive Order 12356,
___

1.3(a)(4), (c), 47 Fed. Reg. 14874, 14876. Accordingly, she

said, the information was properly classified at the "SECRET

level" and was exempt from disclosure under FOIA Exemption 1.

With respect to Exemption 3, which protects

information exempted from disclosure by statute, Stricker

explained that, similar to Executive Order 12356, the

National Security Act, 50 U.S.C. 403(d)(3), requires the

Director of the CIA to protect intelligence sources and

methods from unauthorized disclosure. Stricker concluded

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that the redacted information fell within the ambit of the

statute because it identified the use of particular

intelligence methods used during specific time periods.

According to Stricker, the release of such information would

allow hostile intelligence organizations to neutralize the

use of those methods, thereby causing a concomitant loss of

intelligence.

On November 14, 1990, the district court ordered

the government to give to plaintiff information from three of

the documents subject to in camera review. This included the
__ ______

information at issue here the third full paragraph on page

2 of the December 22, 1961 memo.5 The CIA moved for

reconsideration of the portion of the court's order regarding

the redacted paragraph and submitted an in camera declaration
__ ______

by Stricker, which explained in further detail the nature of

the information withheld. On February 1, 1991, the district

court granted the CIA's motion for reconsideration, but on

reconsideration, the court affirmed its earlier ruling,

finding that "the movant's assertion that disclosure will


____________________

5. The district court's order of November 14, 1990, also
required disclosure of material contained in two other
documents: (1) a single name (E.L. Johnson) contained in an
FBI document dated November 20, 1961; and (2) the third full
paragraph of an FBI memorandum dated July 5, 1962. The FBI
requested the district court to reconsider the portion of the
order regarding the July 5, 1962 memorandum, arguing that the
material was exempt from disclosure under FOIA Exemption 7(D)
as information obtained from a confidential source. The
district court granted the FBI's motion for reconsideration
and vacated that portion of its order on February 1, 1991.

-8-

'reveal its sources and methods' in a matter now

approximately thirty years old is without substance and is,

indeed, the height of bureaucratic disingenuousness." The

CIA appeals from this order.





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A. FOIA Exemption 3
________________

The FOIA gives members of the public access to

documents held in government files. Every federal agency

"upon any request for records which . . . reasonably

describes such records" must make the records "promptly

available to any person." 5 U.S.C. 552(a)(3). Nine

categories of documents are exempted from this broad

disclosure requirement.

Exemption 3 permits a federal agency to

withhold matters that are:

(3) specifically exempted from disclosure
by statute . . . provided that such
statute (A) requires that the matters be
withheld from the public in such a manner
as to leave no discretion on the issue,
or (B) establishes particular criteria
for withholding or refers to particular
types of matters to be withheld.

5 U.S.C. 552(b)(3). Two questions need to be answered in

determining whether Exemption 3 applies in a particular

situation. CIA v. Sims, 471 U.S. 159, 167 (1985). First,
___ ____

does the statute constitute a "statutory exemption to

disclosure within the meaning of Exemption 3"? Second, is

the requested information "included within" the statute's

"protection"? Id.
___

The first question has already been answered

affirmatively for present purposes. In Sims, the Supreme
____

Court held that 50 U.S.C. 403(d)(3), which provides that

"the Director of Central Intelligence shall be responsible
-10-

for protecting intelligence sources and methods from

unauthorized disclosure," is an Exemption 3 statute because

it specifies the types of material to be withheld under

subpart (B) of the Exemption. 471 U.S. at 167-68; accord
______

Knight v. CIA, 872 F.2d 660, 663 (5th Cir. 1989), cert.
______ ___ _____

denied, 494 U.S. 1004 (1990); Miller v. Casey, 730 F.2d 773,
______ ______ _____

777 (D.C. Cir. 1984).

In answering the second question whether the

requested information is included within the statute's

"protection" this court has stated that,

once a court determines that the statute
in question is an Exemption 3 statute,
and that the information requested at
least arguably falls within the statute,
FOIA de novo review normally ends.
__ ____

Aronson v. IRS, 973 F.2d 962, 965, 967 (1st Cir. 1992).
_______ ___

The Supreme Court has said,

it is the responsibility of the Director
of Central Intelligence, not that of the
judiciary, to weigh the variety of
complex and subtle factors in determining
whether disclosure of information may
lead to an unacceptable risk of
compromising the Agency's intelligence-
gathering process.

Sims, 471 U.S. at 180. In the intelligence area, the Court
____

has commented that judges "have little or no background in

the delicate business of intelligence gathering" and may be

unable to comprehend the significance of material that

appears to be innocuous, but in fact can reveal a significant

intelligence source or method. Id. at 176. Therefore, in
___
-11-

determining whether withheld material relates to intelligence

sources or methods, a court must "accord substantial weight

and due consideration to the CIA's affidavits." E.g.,
____

Fitzgibbon v. CIA, 911 F.2d 755, 762 (D.C. Cir. 1990); see
__________ ___ ___

Sims 471 U.S. at 170 ("Congress intended to give the Director
____

of Central Intelligence broad power to protect the secrecy

and integrity of the intelligence process").

We have examined the unredacted version of the

December 22, 1961 memorandum. In our opinion, it is at very

least "arguable" that the requested paragraph falls within 50

U.S.C. 403(d)(3) for the reason the CIA gave, to wit, that

it could reveal intelligence methods. See Sims, 471 U.S. at
___ ____

180-81; Aronson, 973 F.2d at 967. Giving due deference to
_______

the agency's determination, we hold that the paragraph is

exempt from disclosure under FOIA Exemption 3 and 50 U.S.C.



-12-

403(d)(3). The district court erred in ruling otherwise.6

B. FOIA Exemption 1
________________

While our decision under Exemption 3 ends the

matter, we note that FOIA Exemption 1 leads to the same

result. Exemption 1 permits the withholding of matters that

are:

(1)(A) specifically authorized under
criteria established by an Executive
order to be kept secret in the interest
of national defense or foreign policy and
(B) are in fact properly classified
pursuant to such Executive order.

5 U.S.C. 552(b)(1). Executive Order 12356, upon which the

CIA relies, specifically authorizes the withholding of

information concerning "intelligence sources and methods,"


____________________

6. We do not agree with the district court that merely
because the information here is thirty years old, it cannot
detrimentally reveal intelligence sources or methods.
Plaintiff conceded at oral argument before this court that if
the withheld information relates to intelligence sources or
methods, the passage of thirty years, by itself, is
insufficient to require an agency to disclose the
information. Courts have generally rejected the contention
that the mere age of intelligence information rules out
Exemption 3. Fitzgibbon, 911 F.2d at 763-64. Reluctance
__________
stems from recognition that it is virtually impossible for an
outsider to ascertain what effect the passage of time may or
may not have had to mitigate the harm from disclosure of
sources and methods. Such is true, certainly, as to events
that have occurred well within the careers of living persons
including governmental leaders (like Cuba's leader) still in
power. The CIA, not the judiciary, is better able to weigh
the risks that disclosure of such information may reveal
intelligence sources and methods so as to endanger national
security. Courts have accordingly upheld pursuant to
Exemption 3 and 50 U.S.C. 403(d)(3) the withholding of
information as old as that sought by plaintiff here. Sims,
____
471 U.S. at 180 (approximately thirty-year-old information);
Fitzgibbon 911 F.2d at 763-64 (same).
__________

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1.3(a)(4), 47 Fed. Reg. 14874, 14876, and declares that

unauthorized disclosure of "intelligence sources and methods"

is "presumed to cause damage to the national security,"

1.3(c), 47 Fed. Reg. at 14876.

When, as here, Exemptions 1 and 3 are claimed on

the basis of potential disclosure of intelligence sources or

methods, the standard of reviewing an agency's decision to

withhold information is essentially the same.7 Hrones v.
______

CIA, 685 F.2d 13, 17 (1st Cir. 1982); Military Audit Project
___ ______________________

v. Casey, 656 F.2d 724, 736-37 n.39 (D.C. Cir. 1981)
_____

(Exemption 3 and 1 provide overlapping protection in cases

involving intelligence sources and methods); see Sims, 471
___ ____

U.S. at 190 n.6 (Marshall, J., concurring) (current Executive

Order 12356 moves Exemption 1 closer to Exemption 3 than its

predecessor Executive Order 12065). Courts, therefore,

accord substantial deference to the CIA's determination that

information must be withheld under Exemption 1, and will

uphold the agency's decision so long as the withheld

information "logically falls into the category of the

exemption indicated," and there is no evidence of bad faith


____________________

7. Although the standards are substantially identical,
courts, in reviewing Exemption 1 claims, state that their
review is de novo. E.g., Goldberg v. United States Dept. of
__ ____ ____ ________ ______________________
State, 818 F.2d 71, 77 (D.C. Cir. 1987), cert. denied, 485
_____ ____________
U.S. 904 (1988). In carrying out this de novo review, courts
__ ____
"accord substantial weight to an agency's affidavit
concerning the details of the classified status of the
disputed record." S. Conf. Rep. No. 1200, 93d Cong., 2d
Sess. 12 (1974), reprinted in 1974 U.S.C.C.A.N. 6290.
____________

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on the part of the agency. E.g., Bell v. United States, 563
____ ____ _____________

F.2d 484, 487 (1st Cir. 1977); King v. United States Dep. of
____ _____________________

Justice, 830 F.2d 210, 217 (D.C. Cir. 1987). As already
_______

stated, the information withheld by the CIA in this case

"arguably" or "logically" pertains to intelligence methods.

There is no evidence of bad faith on the part of the

agency.8 The redacted paragraph is, therefore, exempt from

disclosure under FOIA Exemption 1 as well as under Exemption

3.9


____________________

8. Plaintiff contends that the district court improperly
denied discovery, which could have revealed agency bad faith.
To support this argument, plaintiff cites Weisberg v. United
________ ______
States Dept. of Justice, 627 F.2d 365, 370-71 (D.C. Cir.
_________________________
1980), in which the D.C. Circuit noted that discovery may be
appropriate when the adequacy of an agency's search is in
doubt. As discussed below, the agencies' affidavits
demonstrate that their searches here were adequate. See
___
Gillin v. IRS, No. 92-1803, slip. op. at 10 (1st Cir.
______ ___
December 7, 1992) (citing Goland v. CIA, 607 F.2d 339, 355
______ ___
(D.C. Cir. 1978)) (absent showing of bad faith sufficient to
impugn agency's affidavit demonstrating adequacy of search,
district court has discretion to forego discovery), cert.
_____
denied, 445 U.S. 927 (1980). In any case, plaintiff's claims
______
that the district court abused its discretion by denying her
discovery are devoid of merit. See infra at 42-43. Thus,
___ _____
Weisberg is inapposite.
________

9. As with Exemption 3, the passage of some thirty years
does not, by itself, invalidate the CIA's showing under
Exemption 1. Executive Order 12356 provides, without time
limit, that "[i]nformation shall be classified as long as
required by national security considerations." 1.4(a), 47
Fed. Reg. at 14877. Unlike its predecessor Executive Order
12065, Executive Order 12356 does not create a presumption
favoring disclosure of information once it reaches a certain
age. Courts have recognized that it would be extremely
difficult for the judiciary to set particular time
limitations upon Exemption 1, at least within time parameters
of the duration we are discussing here. Bonner v. United
______ ______
States Dept. of State, 724 F. Supp. 1028, 1033 n.15 (D.D.C.
_____________________

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2. Plaintiff's Appeal
__________________

Plaintiff alleges numerous errors in the district

court's discovery orders, grants of summary judgment, and

denial of attorney's fees. Plaintiff complains specifically

of the following district court actions: 1) denying

plaintiff's request for Vaughn indices;10 2) ruling that
______

the defendant agencies had conducted adequate searches; 3)

ruling that the government had properly claimed exemptions

under the FOIA; 4) denying various discovery requests; and 5)

denying attorney's fees to plaintiff. We address each of

these claims of error and find that none has any merit.

A. Vaughn Index
____________

____________________

1989), vacated on other grounds, 928 F.2d 1148 (D.C. Cir.
_________________________
1991). In this case, after review of the paragraph in
question, Information Review Officer Stricker concluded that
the "classification [of this information] should be
maintained" in the interests of national security. We are
not in a position to "second-guess" the CIA's conclusion
regarding the need for continued classification of this
material. Branch v. FBI, 700 F. Supp. 47, 48-49 & n.4
______ ___
(D.D.C. 1988); see Sims, 471 U.S. at 178 ("[w]hat may seem
___ ____
trivial to the uninformed, may appear of great moment to one
who has a broad view of the scene and may put the questioned
item of information in its proper context.") (citations and
internal quotations omitted); Bell, 563 F.2d at 486-87
____
(upholding under Exemption 1 the withholding of approximately
thirty-year-old information). But see Wiener v. FBI, 943
_______ ______ ___
F.2d 972, 981 n.15 (9th Cir. 1991) (asking under Executive
Order 12356 whether it is reasonable to expect disclosure of
a twenty-year-old investigation to reveal the existence of a
current intelligence investigation), cert. denied, 112 S. Ct.
____________
3013 (1992).

10. The name of these indices is derived from the seminal
case, Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973), cert.
______ _____ _____
denied, 415 U.S. 977 (1974).
______

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Plaintiff contends that the district court erred in

denying plaintiff's motion to compel each defendant agency to

prepare a Vaughn index. A Vaughn index correlates
______ ______

information that an agency decides to withhold with the

particular FOIA exemption or exemptions, explaining the

agency's justification for nondisclosure. E.g., Curran v.
____ ______

Department of Justice, 813 F.2d 473, 475 n.4 (1st Cir. 1987);
_____________________

Wightman v. Bureau of Alcohol, Tobacco & Firearms, 755 F.2d
________ _____________________________________

979, 981 n.1 (1st Cir. 1985). An adequate Vaughn index
______

serves three functions:

it forces the government to analyze
carefully any material withheld, it
enables the trial court to fulfill its
duty of ruling on the applicability of
the exemption, and it enables the
adversary system to operate by giving the
requester as much information as
possible, on the basis of which he can
present his case to the trial court.

Keys v. United States Dept. of Justice, 830 F.2d 337, 349
____ ______________________________

(D.C. Cir. 1987) (quoting Lykins v. United States Dept. of
______ ______________________

Justice, 725 F.2d 1455, 1463 (D.C. Cir. 1984)). We find no
_______

merit in plaintiff's claim of improper denial of Vaughn
______

indices here.11 A Vaughn index was obviously not
______


____________________

11. Although plaintiff frames her claim as one of improper
denial of Vaughn indices, her brief suggests that plaintiff
______
also contests the adequacy of the Vaughn indices that were,
______
in fact, provided by certain of the defendant agencies.
Because a district court must have an adequate factual basis
for making determinations as to the applicability of claimed
FOIA exemptions, e.g., Bowers v. United States Dept. of
____ ______ ________________________
Justice, 930 F.2d 350, 353 (4th Cir.), cert. denied, 112 S.
_______ ____________
Ct. 308 (1991); Ingle v. United States Dept. of Justice, 698
_____ ______________________________

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called for from the INS, the DIA or the Customs Service.

These agencies disclaimed possession of any documents

material to plaintiff's request. A Vaughn index could not
______

even have been prepared in such circumstances.

As for the CIA, the district court denied

plaintiff's motion for a Vaughn index, without prejudice,
______

because plaintiff had failed to supply the CIA with data

e.g., the city or county of Thompson's birth and a copy of

his birth certificate that the CIA said was necessary to

complete its search. Although plaintiff subsequently

furnished the CIA with the requested information, the record

nowhere indicates that plaintiff renewed her request for a

Vaughn index from the CIA.
______

The CIA did file, in connection with its summary

judgment motion, both public and in camera declarations,
__ ______

asserting that particular information redacted or expressly

withheld was exempt from the FOIA under Exemptions 1 and 3

because it would reveal intelligence sources or methods. One

such declaration was that of Information Review Officer

Stricker. While this lacked specifics, a more detailed

affidavit could have revealed the very intelligence sources

or methods that the CIA wished to keep secret. See, e.g.,
___ ____

____________________

F.2d 259, 263 (6th Cir. 1983), we address both the adequacy
of the agencies' Vaughn indices and the propriety of the
______
district court's decision with respect to plaintiff's initial
motion for Vaughn indices.
______

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Doyle v. FBI, 722 F.2d 554, 556 (9th Cir. 1983) ("In certain
_____ ___

FOIA cases -- usually when national security exemptions are

claimed -- the government's public description of a document

and the reasons for exemption may reveal the very information

that the government claims is exempt from disclosure.");

Church of Scientology v. United States Dept. of Army, 611
_____________________ ___________________________

F.2d 738, 742 (9th Cir. 1979) ("the government need not

specify its objections in such detail as to compromise the

secrecy of the information.").

When, as here, the agency, for good reason, does

not furnish publicly the kind of detail required for a

satisfactory Vaughn index, a district court may review
______

documents in camera. E.g., NLRB v. Robbins Tire & Rubber
__ ______ ____ ____ _____________________

Co., 437 U.S. 214, 224 (1978) ("[t]he in camera review
___ __ ______

provision is discretionary by its terms, and is designed to

be invoked when the issue before the District Court could not

be otherwise resolved"); Church of Scientology, 611 F.2d at
_____________________

742 (if court finds agency affidavits to be "too generalized

to establish eligibility for an exemption, it may, in its

discretion, proceed to examine the disputed documents in
__

camera for a first-hand determination of their exempt
______

status"). Discretionary in camera review enables the court
__ ______

to "determine whether the failure of the affidavit stemmed

from mere inadvertence or from a truly overbroad reading of

the exemption by the agency." Irons v. Bell, 596 F.2d 468,
_____ ____

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471 n.6 (1st Cir. 1979). The government, however, retains at

all times the burden of proving the exempt status of withheld

documents.12 E.g., Church of Scientology, 611 F.2d at 743.
____ _____________________

In camera review is particularly appropriate when
__ ______

the documents withheld are brief and limited in number. See,
___

e.g., Ingle v. Department of Justice, 698 F.2d 259, 264 (6th
____ _____ _____________________

Cir. 1983) ("full in camera reviews are appropriate in cases
__ ______

involving a very limited number of relatively brief

documents"); Church of Scientology, 611 F.2d at 743 ("small
_____________________

number of documents requested, and their relative brevity,

____________________

12. The 1974 amendments to the FOIA, P.L. 93-502, 88 Stat.
1561, 1562 (1974), expressly state that the government
retains the burden of proving a document's exempt status even
when a district court conducts in camera review:
__ ______

[The district court] may examine the contents of such
agency records in camera to determine whether such
records or any part thereof shall be withheld under any
of the exemptions set forth in subsection (b) of this
section, and the burden is on the agency to sustain its
action.

5 U.S.C. 552(a)(4)(B). The legislative history of the 1974
amendments to the FOIA further clarifies the district court's
discretion in conducting in camera review and the
__ ______
government's burden of proof:

While in camera examinations need not be automatic, in
__ ______
many situations it will plainly be necessary and
appropriate. Before the court orders in camera
__ ______
inspection, the Government should be given the
opportunity to establish by means of testimony or
detailed affidavits that the documents are clearly
exempt from disclosure. The burden remains on the
Government under this law.

S. Conf. Rep. No. 1200, 93d Cong., 2d Sess. 9 (1974),
reprinted in 1974 U.S.C.C.A.N. 6267, 6287-88.
____________

-20-

made these cases appropriate instances for exercise of the

district court's inspection prerogative."). On the other

hand, "where the documents in issue constitute hundreds or

even thousands of pages, it is unreasonable to expect a trial

judge to do as thorough job of illumination and

characterization as would a party interested in the case."

Vaughn v. Rosen, 484 F.2d 820, 825 (D.C. Cir. 1973), cert.
______ _____ _____

denied, 415 U.S. 977 (1974).
______

The district court here conducted an in camera
__ ______

inspection of the relatively limited number of documents in

which the CIA claimed exemptions. This provided an adequate

factual basis for the district court's decision and obviated

the need for further Vaughn indices from the CIA. See, e.g.,
______ ___ ____

Irons, 596 F.2d at 471 (in camera inspection of documents
_____ __ ______

along with in camera testimony can fully establish
__ ______

applicability of FOIA exemption); King, 830 F.2d at 228
____

(after holding that Vaughn index was inadequate, D.C. Circuit
______

suggests that district court on remand can review documents

in camera).
__ ______

With respect to the State Department, the district

court denied plaintiff's request for a Vaughn index because
______

plaintiff did not contest the adequacy of the State

Department's claimed exemption. The State Department

reported that it had found four documents responsive to

plaintiff's request. It released three of these in their

-21-

entirety and the fourth with minor excisions to protect

personal privacy interests pursuant to FOIA Exemption 6. The

plaintiff did not challenge the excisions under Exemption 6,

rendering unwarranted a Vaughn index at that time. The State
______

Department subsequently submitted a declaration, explaining

that it had withheld names and other identifying information,

such as date and place of birth, address and occupation, of

persons other than plaintiff's deceased husband, because

"disclosure could subject these individuals or their families

to possible embarrassment or harassment." This declaration

fully met any requirement under Vaughn that the State
______

Department provide a reasoned justification for its

withholdings. Furthermore, the State Department submitted

the one redacted document to the district court for in camera
__ ______

review.

Finally, in respect to the FBI, the district court

granted plaintiff's motion for a Vaughn index. The FBI
_______ ______

thereupon submitted two detailed declarations by David R.

Lieberman, a special agent in the Freedom of Information-

Privacy Acts Section of the FBI. Mr. Lieberman explained

that the FBI had released twenty-five of forty-four pages of

material to plaintiff, and justified, by means of coded

indices,13 the withholding of information in order to


____________________

13. In a "coded" format, an agency breaks down its FOIA
exemptions into subcategories, explains the nondisclosure
rationale for each subcategory, and then correlates the

-22-

protect the personal privacy of former FBI agents and third

parties (Exemption 7(C)) and to protect the identities of and

information provided by confidential sources (Exemption

7(D)). Furthermore, as with the CIA and the State

Department, the government submitted all of the FBI's

documents for in camera review. The Lieberman declarations
__ ______

and coded indices, in conjunction with the district court's

in camera review of the documents, were adequate to meet any
__ ______

requirements under Vaughn that the government provide a
______

reasoned justification for its withholdings. See, e.g.,
___ ____

____________________

subcategories to each document or portion withheld. For
example, the Lieberman declaration was accompanied by copies
of the documents in their redacted form. Next to each
redaction was a code designation that corresponds to a FOIA
exemption and a subcategory of information. For instance,
one of the subcategories for information withheld under
Exemption 7(C) was names and initials of FBI agents and
support personnel. A coded symbol (b7C-1) would appear next
to any deletions that fit within this exemption and
subcategory of information. Use of coded indices has been
explicitly approved by several circuit courts as long as each
deletion is correlated "specifically and unambiguously to the
corresponding exemption," and the agency affidavit places
"each document into its historical and investigative
context." See, e.g., Keys v. United States Dept. of Justice,
___ ____ ____ ______________________________
830 F.2d 337, 349-50 (D.C. Cir. 1987). Use of coded indices
is fully consistent with the Supreme Court's endorsement of
"workable rules," under which general categories of
information may be withheld under certain FOIA exemptions
"without regard to individual circumstances." See United
___ ______
States Dept. of Justice v. Reporters Committee for Freedom of
_______________________ __________________________________
the Press, 489 U.S. 749, 779-80 (1989) (upholding use of
_________
categorical rules in Exemption 7(C) context). We therefore
agree with these circuits that "it is the function, not the
form, of the index that is important," and that coded indices
can, in some instances, accomplish the functions of Vaughn
______
"more efficiently and clearly than would the classical Vaughn
______
indices." Keys, 830 F.2d at 349.
____

-23-

Lykins, 725 F.2d at 1464 (when "an agency has released most
______

of the contents of a document and has otherwise met its FOIA

obligations in good faith, a public statement that the

remaining small portions would reveal a confidential source -

- coupled with in camera review of the excised portions of
__ ______

the document . . . is sufficient to meet Vaughn's
______

requirements.").

Plaintiff's claim of improper denial of Vaughn
______

indices is, therefore, groundless and unsupported.

C. The Adequacy of the Searches
____________________________

Plaintiff next contends that the defendant agencies

did not conduct adequate searches for responsive documents.

Plaintiff directs most of her brief to this argument.

However, as with plaintiff's arguments regarding the

defendant agencies' Vaughn indices, plaintiff's contentions
______

with respect to the adequacy of the agencies' searches lack

merit and, in some instances, ignore agency affidavits that

cure deficiencies noted by the district court in earlier

affidavits.

The adequacy of an agency's search for documents

under the FOIA is judged by a standard of reasonableness and

depends upon the facts of each case. E.g., Weisberg v.
____ ________

United States Dept. of Justice, 745 F.2d 1476, 1485 (D.C.
______________________________

1984). The crucial issue is not whether relevant documents

might exist, but whether the agency's search was "reasonably

-24-

calculated to discover the requested documents." Safecard
________

Servs., Inc. v. S.E.C., 926 F.2d 1197, 1201 (D.C. Cir. 1991).
____________ ______

In order to establish the adequacy of its search,

the agency may rely upon affidavits provided they are

relatively detailed and nonconclusory, and are submitted by

responsible agency officials in good faith. E.g., Miller v.
____ ______

United States Dept. of State, 779 F.2d 1378, 1383 (8th Cir.
____________________________

1985); Weisberg, 745 F.2d at 1485. A satisfactory agency
________

affidavit should, at a minimum, describe in reasonable detail

the scope and method by which the search was conducted. See,
____

e.g., Oglesby, 920 F.2d at 68; Perry v. Block, 684 F.2d 121,
____ _______ _____ _____

127 (D.C. Cir. 1982). The affidavit should additionally

"describe at least generally the structure of the agency's

file system which makes further search difficult." Church of
_________

Scientology of Cal. v. I.R.S., 792 F.2d 146, 151 (D.C. Cir.
___________________ ______

1986) (Scalia, J.).

If an agency fails to establish through reasonably

detailed affidavits that its search was reasonable, the FOIA

requester may avert summary judgment merely by showing that

the agency might have discovered a responsive document had

the agency conducted a reasonable search. E.g., Weisberg v.
____ ________

United States Dept. of Justice, 705 F.2d 1344, 1351 (D.C.
______________________________

Cir. 1983). However, if an agency demonstrates that it has

conducted a reasonably thorough search, the FOIA requester

-25-

can rebut the agency's affidavit only by showing that the

agency's search was not made in good faith. Miller, 779 F.2d
______

at 1383. An agency's affidavit is "accorded a presumption of

good faith, which cannot be rebutted by 'purely speculative

claims about the existence and discoverability of other

documents.'" Safecard Servs., 926 F.2d at 1200 (quoting
_______________

Ground Saucer Watch, Inc. v. CIA, 692 F.2d 770, 771 (D.C.
_________________________ ___

Cir. 1981)).

Plaintiff complains, first, that the FBI, the

Customs Service, and the State Department failed to search

"alternate spellings" and "files containing the information

of cohorts." Plaintiff also charges that unspecified "clues"

contained in the four documents released to her by the State

Department "might have indicated" other potential

repositories of information that the State Department should

have searched. Plaintiff's FOIA request, however, was

limited to "information pertaining to Robert Thompson."14

Because the scope of a search is limited by a plaintiff's

FOIA request, there is no general requirement that an agency

search secondary references or variant spellings. See Gillin
___ ______

v. IRS, No. 92-1803, slip op. at 6 (1st Cir. December 7,
___

1992) (quoting Meeropol v. Meese, 790 F.2d 942, 955 (D.C.
________ _____


____________________

14. Plaintiff sent identical FOIA requests to each defendant
agency stating the following: "I am requesting, through the
FOIA, any information you may have concerning my former
husband, Robert Thompson. He disappeared along with Robert
Swanner on a flight over Cuba in December of 1961."

-26-

Cir. 1986)) ("The adequacy of an agency's search 'is measured

by the reasonableness of the effort in light of the specific

request.'"). Nor is there any requirement that an agency

conduct further searches on the basis of unspecified "clues"

in released documents.

Second, plaintiff complains that the declarations

submitted by the FBI and the CIA were not based on personal

knowledge. However, an agency need not submit an affidavit

from the employee who actually conducted the search.

Instead, an agency may rely on an affidavit of an agency

employee responsible for supervising the search. E.g.,
____

Safecard Servs., 926 F.2d at 1201; cf. Weisberg v. United
_______________ ___ ________ ______

States Dept. of Justice, 627 F.2d 365, 369 (D.C. Cir. 1980)
_______________________

(court holds that affidavit was inadequate because it was not

based upon personal knowledge of affiant or anyone else),

appeal on remand, 705 F.2d 1344 (D.C. Cir. 1983). Here, the
________________

FBI submitted several declarations of David Lieberman, a