National Council of La Raza v. Department of Justice
Plaintiff advocacy organizations brought this Freedom of Information Act (FOIA) action to compel the Department of Justice (DOJ) to produce records concerning the authority of state and local police to enforce immigration laws. The DOJ asserted that the documents were protected by Exemption 5, citing deliberative process and attorney-client privileges. The court found that most withheld documents were covered by the deliberative process privilege. However, it ruled that the DOJ waived its privilege for the April 2002 Office of Legal Counsel (OLC) memorandum (Document 28) because the Attorney General and his representatives repeatedly invoked it publicly to justify their policy. Consequently, the court partially granted and partially denied the DOJ's motion for summary judgment, ordering the production of Document 28 and requiring in camera inspection for documents 23-25.