Sixth Circuit -- Michael Rimmer v. Eric Holder, Jr.

Death penalty deft seeking disclosures on prosc investigation via FOIA

No error in FOIA denial, as statutory protections of third parties justified the redaction, and the purpose of the statute is to prevent federal misdeeds, not state ones.

APA cannot be used to review the denial, as petitioner could have challenged the FOIA denial de novo in the District Court. 

Docs could have been requested using a simple agency request (Touhy request).


Michael Rimmer v. Eric Holder, Jr. 

["thou shalt not kill" - MB]