FIA-20-0006 - In the Matter of Carrie Williamson

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On November 7, 2019, the Office of Hearings and Appeals (OHA) denied a Freedom of Information Act (FOIA) appeal filed by Ms. Carrie Williamson (Appellant) concerning a FOIA request she made to the Department of Energy's (DOE) Office of Inspector General (OIG). The Appellant's FOIA request sought a copy of the OIG's determination concerning allegations she had referred to the OIG that a DOE contractor was in breach of a DOE contract. The OIG provided the Appellant with a copy of a complaint form summarizing the Appellant's allegations and indicating that the case had been closed. The OIG indicated in its response that it had redacted the name of the OIG employee who had received the Appellant's referral pursuant to Exemptions 6 and 7(C) of the FOIA. On appeal, the Appellant alleged that the OIG improperly redacted the name of the OIG employee, and that she was entitled to know why the OIG had not taken additional action relating to her allegations. The OHA concluded that the OIG employee had a privacy interest in the non-disclosure of her name under Exemption 7(C) of the FOIA, and that the Appellant had not identified any countervailing public interest in the disclosure of the OIG employee's name. The OHA therefore concluded that the OIG had properly asserted Exemption 7(C). The OHA further concluded that the FOIA did not require the OIG to respond to the Appellant's questions concerning its investigative determinations. For these reasons, the OHA denied the Appellant's appeal. OHA Case No. FIA-20-0006.