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Keywords

motionsummary judgmentmotion for summary judgment
motionsummary judgmentmotion for summary judgment

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Dilley Pro Bono Project v. Immigration and Customs Enforcement

Facts

The ACLU submitted a FOIA request to ICE on October 3, 2018, seeking five categories of spreadsheet data related to immigration enforcement. The request included a demand for unique identifiers to replace A-numbers, which are personal identifiers protected from disclosure under FOIA. ICE conducted a search of its databases and produced over one million rows of data but did not provide the requested unique identifiers, arguing that it lacked the capability to generate them without creating new records.

The ACLU submitted a FOIA request to ICE on October 3, 2018, seeking five categories of spreadsheet data related to immigration enforcement.

Issue

Whether the FOIA requires ICE to replace A-numbers with unique identifiers as requested by the ACLU.

Whether the FOIA requires ICE to replace A-numbers with unique identifiers as requested by the ACLU.

Rule

FOIA does not require agencies to create new records in response to requests; agencies are only obligated to provide access to documents they have created and retained.

FOIA does not require agencies to create new records in response to requests; agencies are only obligated to provide access to documents they have created and retained.

Analysis

The court determined that the ACLU's request for unique identifiers would necessitate the creation of new records, which is not required under FOIA. ICE's assertion that it could not provide unique identifiers without creating a new program to generate them was upheld, as the court found that the request exceeded the agency's obligations under FOIA.

The court determined that the ACLU's request for unique identifiers would necessitate the creation of new records, which is not required under FOIA.

Conclusion

The court denied the ACLU's motion for summary judgment and granted ICE's motion, concluding that ICE was not required to provide unique identifiers in place of A-numbers.

The court denied the ACLU's motion for summary judgment and granted ICE's motion, concluding that ICE was not required to provide unique identifiers in place of A-numbers.

Who won?

United States Immigration and Customs Enforcement (ICE) prevailed in the case because the court found that the ACLU's request would require the creation of new records, which FOIA does not mandate.

United States Immigration and Customs Enforcement (ICE) prevailed in the case because the court found that the ACLU's request would require the creation of new records, which FOIA does not mandate.

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