Ayyakkannu Manivannan v. Department of Energy

When a person requests records from a federal agency under the Freedom of Information Act, may the agency redact the requester’s own name from the requested records, over requester’s objection, on the grounds of protecting the requester from an “unwarranted invasion” of the his or her “personal privacy” under 5 U.S.C. § 552(b)(6) and/or § 552(b)(7)(C)? May the agency similarly redact the name of a public official from an official communication under those statutes on the ground of protecting the public official’s personal privacy?

May a federal circuit court hold that a person failed to exhaust their administrative remedies under the Freedom of Information Act and deny the requester the right to file suit even though the federal agency failed to issue a final determination on his request within the 20-day statutory time limit under 5 U.S.C. 552(a)(6)(C)(i), where the circuit court’s decision irreconcilably conflicts with a chorus of other federal circuit court decisions, federal district courts decisions, a letter from the agency telling the requester had exhausted his remedies, and previous rulings by the agency’s own Office of Hearing and Appeals?