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Celestino G. Almeda v. Department of Education, et al.

Paid petition · United States Court of Appeals for the District of Columbia Circuit, No. 20-5087 · judgment August 18, 2020


Certiorari denied · March 22, 2021
Pre-decision estimate: 2% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

The questions presented are:

  1. Whether publicly-known, purely factual content selected, organized, and recited in an agency’s records can be fully withheld from disclosure under the deliberative process privilege in Exemption 5 of the Freedom of Information Act, 5 U.S.C. § 552(b)(5).

  2. Whether the presumption of good faith attached to an agency’s representation that it released all “reasonably segregable portion[s] of a record” otherwise withheld from disclosure under the deliberative process privilege, 5 U.S.C. §§ 552(b) & (b)(5), is rebutted by evidence that would warrant a belief by a reasonable person that segregable portions instead were withheld.

Counsel of record

For petitioner
Seth Alain Watkins
WATKINS LAW & ADVOCACY, PLLC

For respondent
Brian H. Fletcher
Acting Solicitor General

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Mar 22 2021
    Petition DENIED.
  2. Mar 03 2021
    DISTRIBUTED for Conference of 3/19/2021.
  3. Feb 23 2021
    Waiver of right of respondent United States Department of Education, et al. to respond filed.
  4. Jan 15 2021
    Petition for a writ of certiorari filed. (Response due February 24, 2021)