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Fed Prisoner's FOIA Request for Investigation-Related Documents Properly Denied

In 1997, Willie E. Boyd, a federal prisoner, was convicted of charges related to a gun and bag of cocaine found in his girlfriend's closet. He later discovered that his girlfriend's brother was a government informant who had sold drugs in the past. He filed disclosure requests under the federal Freedom of Information Act (FOIA), 5 U.S.C. § 552 et seq., for documents related to his girlfriend's brother's drug dealing and snitching endeavors. The Bureau of Alcohol, Tobacco and Firearms denied some of his FOIA requests; a federal district court upheld the denials, and Boyd appealed.

On appeal, the U.S. Court of Appeals for the District of Columbia found that: (1) the documents were properly withheld under § 552(b)(7)(a) because disclosing them would hamper an ongoing investigation; (2) the documents were properly withheld under § 552(b)(7)(c) because there was no overriding public interest requiring disclosure; and (3) the documents were properly withheld under § 552(b)(7)(d) in order to maintain the autonomy of a confidential informant. Thus, the district court was affirmed. See: Boyd v. Criminal Div. of U.S. Dept. of Justice, 475 F.3d 381 (D.C. Cir. 2007).

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Related legal case

Boyd v. Criminal Div. of U.S. Dept. of Justice