Anthony Viola v. US Department of Justice

3rd CircuitNov 3, 2025

Split Score

SplitScore: 58/100

Case Summary

Disposition

Affirmed in Part

The Third Circuit reviewed Anthony Viola’s FOIA suit against DOJ components and a county mortgage-fraud task force. It affirmed dismissal of the task-force defendant for lack of personal jurisdiction and largely upheld the agencies’ searches, but it vacated portions of the summary judgment that approved several FOIA withholdings, sending the case back for further proceedings on those issues.

Circuit Split Identified

Legal Issue

Whether the "risk of circumvention of the law" clause in FOIA Exemption 7(E) applies to both the "techniques-and-procedures" prong as well as the "guidelines" prong, or only to the guidelines prong.

Circuit Positions

3rd Circuit(this circuit)

Risk-of-circumvention showing required for BOTH prongs of Exemption 7(E).

2nd Circuit4th Circuit9th Circuit

Risk-of-circumvention showing required ONLY for the guidelines prong of Exemption 7(E).

Conflict Summary

The Third Circuit (following its prior decision in Davin) requires agencies to show that disclosure could reasonably be expected to risk circumvention of the law for BOTH the techniques-and-procedures prong and the guidelines prong of Exemption 7(E). The Second, Fourth, and Ninth Circuits hold that the risk-of-circumvention showing is necessary only when an agency withholds investigative *guidelines*; no such showing is required for materials describing investigative techniques or procedures.

Parties & Counsel

Parties

Appellant:Anthony L. Viola
Appellee:United States Department of Justice, Federal Bureau of Investigation, Executive Office for United States Attorneys, and Cuyahoga County Mortgage Fraud Task Force

Legal Counsel

Appellant:Alan Chen; Daniel Mejia-Cruz (Yale Law School Advanced Appellate Litigation Project); Tadhg Dooley; David R. Roth (Wiggin & Dana LLP)
Appellee:Laura S. Irwin (U.S. Attorney's Office, W.D. Pa.); Sharon Swingle; Daniel Winik (U.S. DOJ Civil Division, Appellate); Jake A. Elliott (Cuyahoga County Prosecutor’s Office)

Opinion Document