FIA-20-0022 - In the Matter of Michael Ravnitzky

On April 1, 2020, the Office of Hearings and Appeals (OHA) denied a Freedom of Information Act (FOIA) Appeal filed by Michael Ravnitzky (Appellant) from a final determination issued by the Department of Energy's National Office of Public Information ( OPI). On Appeal, the Appellant alleged that OPI had not conducted an adequate search because it would be "odd" if the requested records did not exist. He further argued that OPI's determination did not include sufficient context. After review, OHA determined that DOE's
limited search was guided by personal knowledge that no responsive records existed and that, therefore, the search was reasonable. OHA further determined that OPI's determination letter met the minimum requirements of the FOIA. Accordingly, the Appeal was denied. OHA Case No. FIA-20-0022.