context: Similarly, it is difficult to imagine non-investigatory documents eligible for withholding under Exemption 7(E) that could pass through the Exemption 7 threshold under the district court's interpretation. Thus, were we to deny the application of Exemption 7 to generalized law enforcement documents simply because the government could not link them to enforcement of a specific law, the additional protections that Congress provided to those very documents in Exemption 7(E) would be nullified. Indeed, we have implicitly adopted this approach by analyzing documents under Exemption 7(E) without questioning whether they were "compiled for law enforcement purposes."
citation_a.signal: see also
citation_a.parenthetical: analyzing a FOIA request for law enforcement techniques and guidelines under Exemption 7(E
citation_a.sentence: See Hamdan v. U.S. Dep’t of Justice, 797 F.3d 759, 777-78 (9th Cir. 2015) (upholding the FBI’s withholding of documents containing law enforcement techniques for surveillance and credit searches under Exemption 7(E)); see also ACLU of N. Cal. v. U.S. Dep’t of Justice, 880 F.3d 473, 2018 WL 455857 (9th Cir. Jan. 18, 2018) (analyzing a FOIA request for law enforcement techniques and guidelines under Exemption 7(E)).
citation_b.signal: see
citation_b.identifier: 797 F.3d 759, 777-78
citation_b.parenthetical: upholding the FBI's withholding of documents containing law enforcement techniques for surveillance and credit searches under Exemption 7(E
citation_b.sentence: See Hamdan v. U.S. Dep’t of Justice, 797 F.3d 759, 777-78 (9th Cir. 2015) (upholding the FBI’s withholding of documents containing law enforcement techniques for surveillance and credit searches under Exemption 7(E)); see also ACLU of N. Cal. v. U.S. Dep’t of Justice, 880 F.3d 473, 2018 WL 455857 (9th Cir. Jan. 18, 2018) (analyzing a FOIA request for law enforcement techniques and guidelines under Exemption 7(E)).