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Jorge Alejandro Rojas v. Federal Aviation Administration

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 17-55036 · judgment March 2, 2021


Certiorari denied · January 10, 2022
Pre-decision estimate: 6% cert probability (95% interval 4%–8%)

Before the decision, modestly above the 4.1% base rate. The model weighted this up for a Ninth Circuit decision below, a circuit split argued in the petition, and a dissent in the court below (flagged in the petition).

Question presented

Exemption 5 of the Freedom of Information Act provides that federal agencies need not release privileged “inter-agency or intra-agency memorandums or letters.” 5 U.S.C. § 552(b)(5). Seven courts of appeals have interpreted the phrase “intra-agency . . . memorandums or letters” to include a “consultant corollary,” shielding from disclosure documents drafted by private, outside parties and sent to federal agencies. One court of appeals has rejected this atextual approach. The question presented is: Whether the Ninth Circuit, in a sharply divided en banc decision, erred by adopting the consultant corollary and holding that “intra-agency memorandums or letters” in FOIA’s Exemption 5 encompasses documents prepared by APTMetrics, a private, outside consultant.

Counsel of record

For petitioner
Naomi Jean Scotten
Orrick, Herrington & Sutcliffe LLP

For respondent
Elizabeth B. Prelogar
Solicitor General

Case

Conference history
Distributed for 1 conference

Amicus briefs
1 cert-stage

Proceedings

  1. Jan 10 2022
    Petition DENIED.
  2. Dec 15 2021
    DISTRIBUTED for Conference of 1/7/2022.
  3. Dec 13 2021
    Reply of petitioner Jorge Alejandro Rojas filed. (Distributed)
  4. Nov 29 2021
    Brief of respondent Federal Aviation Administration in opposition filed.
  5. Oct 26 2021
    Motion to extend the time to file a response is granted and the time is further extended to and including November 29, 2021.
  6. Oct 22 2021
    Motion to extend the time to file a response from November 1, 2021 to November 29, 2021, submitted to The Clerk.
  7. Sep 27 2021
    Motion to extend the time to file a response is granted and the time is further extended to and including November 1, 2021.
  8. Sep 24 2021
    Motion to extend the time to file a response from October 1, 2021 to November 1, 2021, submitted to The Clerk.
  9. Sep 01 2021
    Brief amicus curiae of Cato Institute filed.
  10. Aug 16 2021
    Motion to extend the time to file a response is granted and the time is extended to and including October 1, 2021.
  11. Aug 13 2021
    Motion to extend the time to file a response from September 1, 2021 to October 1, 2021, submitted to The Clerk.
  12. Jul 29 2021
    Petition for a writ of certiorari filed. (Response due September 1, 2021)