Immigration Law

'FOIA Requests Are Not a Game of Battleship' - GAP v. DHS

GAP v. DHS - "FOIA requests are not a game of Battleship. The requester should not have to score a direct hit on the records sought based on the precise phrasing of his request. Rather, the agency must liberally interpret the request and frame its search accordingly. Guided by Summers and Bagwell, the Court concludes that DHS neither liberally construed GAP’s request, Nation Magazine, 71 F.3d at 890, nor conducted a search reasonably likely to produce all responsive records, Ancient Coin Collectors Guild, 641 F.3d at 514. Therefore, it will order DHS to conduct an additional search of its records."