Karl Gallant v. National Labor Relations Board
Court of Appeals for the D.C. Circuit
1Opinion of the Court
Opinion for the Court filed by Circuit Judge SENTELLE.
SENTELLE, Circuit Judge:
Karl Gallant, a disappointed FOIA requester, appeals from an order granting summary judgment in his action to obtain from the NLRB documentary records of the efforts of a Board member to secure her own reappointment. He contends on appeal that the District Court erred in ruling that the documents were not agency records, and that certain information was protected by privacy exemptions under the FOIA. Because we perceive no error in either ruling, we affirm.
I. BACKGROUND
In 1991, as her term as a Member of the…
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