ELR Citation: 53 ELR 20098
No(s). 1:19-cv-03307 (TNM) (D.D.C. Jun 27, 2023) (McFadden, J.)

A district court granted summary judgment for the State Department in a lawsuit concerning documents related to the agency's handling of the 2016 Paris Climate Agreement. A nonprofit group filed a FOIA request, seeking three documents concerning the "Circular 175" process for the agreement. The Department moved for summary judgment, arguing it properly redacted information in the documents pursuant to the deliberative process and attorney-client privileges and contending it produced all reasonably segregable material. The court found the agency adequately demonstrated both privileges and satisfied its segregability burden. It granted summary judgment for the Department.