Kalbers v. Volkswagen AG

Kalbers · United States Court of Appeals for the Ninth Circuit · January 30, 2026 · No. 24-1048; 24-1477

Summary

The Ninth Circuit addressed whether the Freedom of Information Act requires disclosure of millions of documents that Volkswagen provided to federal prosecutors in response to a grand jury subpoena. The court held that Federal Rule of Criminal Procedure 6(e), incorporated through FOIA Exemption 3, protects nearly all of the requested documents because disclosure would reveal matters occurring before the grand jury. It reversed in part, vacated in part, and remanded for evaluation of four documents lacking a Rule 6(e) label.

Court
United States Court of Appeals for the Ninth Circuit
Writing for the Court
Ryan D. Nelson; Milan D. Smith, Jr.; David A. Ezra, District Judge, sitting by designation
Jurisdiction
United States Court of Appeals for the Ninth Circuit
Decision date
January 30, 2026
Docket number
24-1048; 24-1477
Procedural posture
Appeals by the Department of Justice and Volkswagen AG from the Central District of California's order denying the Department's petitions for protection under Federal Rule of Criminal Procedure 6(e) and requiring disclosure of documents responsive to Kalbers's FOIA request.
Standard of review
De novo review of the district court's interpretation and application of Federal Rule of Criminal Procedure 6(e). The court also reviewed the final disclosure order under 28 U.S.C. § 1291.
Precedential value
published
Parties
United States Department of Justice, Volkswagen AG v. Lawrence P. Kalbers
Disposition
reversed_and_remanded

Topics

judicial review of agency actionadministrative lawappellate jurisdictionstandard of reviewstatutory interpretation

Practice areas

administrative lawappellate procedurecriminal procedurestatutory interpretation

Questions Presented

  1. Whether the district court's order granting disclosure under Federal Rule of Criminal Procedure 6(e) was a final decision reviewable under 28 U.S.C. § 1291.
  2. Whether documents that the government possesses only because they were produced in response to a grand jury subpoena constitute a matter occurring before the grand jury protected by Rule 6(e).
  3. Whether FOIA Exemption 3 incorporates Rule 6(e) and therefore permits the Department of Justice to withhold nearly all of the subpoenaed documents.
  4. Whether the four documents lacking a Rule 6(e) label should be evaluated separately for possible disclosure.

Holdings

  1. An order granting disclosure under Rule 6(e) is a final decision reviewable under 28 U.S.C. § 1291, and consolidation with the FOIA action did not eliminate the appellants' right to appeal.
  2. Documents that the government possesses only because they were produced in response to a grand jury subpoena are a matter occurring before the grand jury when disclosure would reveal the subpoena, the grand jury's investigation, or its deliberative process.
  3. The preexisting-documents or independent-source exception does not apply when the government possesses the requested documents only through the grand jury subpoena and not through an independent source.
  4. Rule 6(e), incorporated through FOIA Exemption 3, bars disclosure of nearly all six million documents because the Department obtained them only through a grand jury subpoena, the documents were marked as produced pursuant to Rule 6(e), and disclosure would reveal matters before the grand jury.

Key quotations

Thus, a rule that prohibits disclosing “matter[s] occurring before the grand jury” bars revealing any “subject” under the grand jury’s consideration. (11-12)
Thus, the government may defeat a request to reveal documents subpoenaed by a grand jury by disproving any of the following: (1) that the documents are in governmental possession from an independent source; (2) that the documents were sought for a reason independent of the grand jury investigation; or (3) that disclosure of the documents would not otherwise compromise the integrity of the grand jury process. (21)
If the grand jury investigated Volkswagen’s internal emails or technical documents, the Rule protects the fact of that investigation from disclosure. (26)

Factual background

The Department of Justice investigated Volkswagen's use of defeat-device software and obtained approximately 5.9 to 6 million documents from Volkswagen's counsel, Jones Day, in response to a federal grand jury subpoena. Nearly all of the documents were marked as produced pursuant to Rule 6(e), while four documents lacked that label. Kalbers submitted a FOIA request seeking the factual evidence Jones Day presented to the Department, and the district court ordered disclosure of the responsive documents.

Procedural history

Kalbers sought under FOIA documents Volkswagen provided to the Department of Justice during its criminal investigation and plea negotiations. The district court consolidated the FOIA action with the Department's Rule 6(e) petitions, referred the matters to a special master, overruled objections to the special master's recommendation, and denied the Department's petitions in a minute order. The Department and Volkswagen appealed.

Remand instructions

The district court's order requiring disclosure of the nearly six million documents was reversed. The order was vacated as to the four documents lacking a Rule 6(e) label, and the district court was directed to evaluate whether the government must disclose those four documents.

Court Document

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