Texas Public Policy Foundation v. U.S. Department of State

The plaintiff argued that the Department failed to conduct a sufficient search of records concerning the Special Presidential Envoy for Climate and improperly redacted names and agency email addresses. The court found that the Department’s declaration sufficiently demonstrated that its search was reasonably calculated to yield responsive records, shifting the burden to the plaintiff to present evidence of a genuine issue regarding the adequacy of the search. The court rejected the plaintiff’s claim that official business communications were located in the special envoy’s personal email account, deeming it speculative, and upheld the Department’s summary judgment on the issue. Additionally, the court affirmed the Department’s decision to withhold draft iterations of greenhouse gas emissions policies under FOIA Exemption 5, recognizing that early drafts may not reflect final policy decisions made by the White House. Lastly, the court determined that the redaction of names and email addresses of specific Department employees was justified under FOIA exemptions, citing both the employees’ privacy interests and the lack of substantive information in the redacted details that would further illuminate the Department’s role in formulating the NDCs.