Summary
The District Court for the District of Columbia granted the FDA’s renewed motion for summary judgment and denied ICAN’s renewed cross-motion in a FOIA action seeking autopsy reports concerning deaths reported after COVID-19 vaccination. The court held that FOIA Exemption 6 permitted withholding identifying information because disclosure could allow decedents to be identified and invade their surviving family members’ privacy. It further concluded that the remaining non-exempt material consisted only of boilerplate form language and therefore had minimal or no information content after redaction.
Court
United States District Court for the District of Columbia
Jurisdiction
United States District Court for the District of Columbia
Decision date
March 3, 2026
Docket number
22-3572 (CKK)
Disposition
other
Questions Presented
- Whether FOIA Exemption 6 permits the FDA to withhold information from autopsy reports that could be used, in combination with other available information, to identify decedents and invade their families' privacy.
- Whether the FDA demonstrated that the autopsy reports contain no reasonably segregable, nonexempt information requiring disclosure after redaction.
Holdings
- FOIA Exemption 6 permits the FDA to withhold information in the autopsy reports that could reasonably be used, alone or through a mosaic of information combined with other publicly available data, to identify decedents and thereby invade their surviving family members' personal privacy.
- The FDA may withhold the autopsy reports in their entirety because, after redacting the exempt personally identifying information, the remaining material would have minimal or no information content and therefore is not reasonably segregable for disclosure.
Court Document
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