Competitive Enterprise Institute v. United States Environmental Protection Agency
District Court, District of Columbia
1Opinion of the Court
OPINION
ROSEMARY M. COLLYER, United States District Judge
Administrators of the Environmental Protection Agency have made prolific use of government-issued smart phones to send thousands of text messages. Based on its knowledge of this practice, Competitive Enterprise Institute submitted two requests under the Freedom of Information Act for certain officials’ text messages, on the assumption that some of those messages would contain substantive agency communications. The Agency responded that it identified no records responsive to these requests because the text messages were not “records” that…
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