Stevens v. United States Department of State, No. 20-3504 (7th Cir. 2021)
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Stevens, a Political Science professor at Northwestern University, researching the relations between the foreign campuses of American universities, the federal government, and private‐sector entities, submitted Freedom of Information Act requests to the State Department. She sought all materials from the Department’s headquarters and the Qatar U.S. consulate referring to Northwestern’s Qatar campus; policy and planning materials relating to the establishment of U.S. university campuses in Qatar, Abu Dhabi, South Korea, China, and Singapore; and documents sent to or from the U.S. Agency for International Development and documents produced, received, or maintained by the Middle East Partnership Initiative relating to U.S. Government funds transferred to the Independent Center of Journalists, Northwestern University and its components, and the Center of Journalism Excellence. After Stevens filed suit, the Department provided Stevens with 128 complete records and 350 partial records responsive to the Northwestern request, 29 complete records and two partial records responsive to the USAID/MEPI request, and no records responsive to the Campuses request. It withheld 24 records and submitted a 35‐page declaration describing its search processes and a Vaughn index describing each withheld document and the grounds for withholding it.
The Seventh Circuit affirmed summary judgment in favor of the Department, rejecting arguments that summary judgment was improper because the Department’s searches were inadequate and because its withholdings were unwarranted.
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