In a case before U.S. District Court Judge for the District of Columbia Colleen Kollar-Kotelly, it has been held that the government has failed to establish that Exemption 5 and 7(A) apply for withholding certain documents.
It wasn't a complete loss for the government, as the court found many of the documents to be exempt from the FOIA. However, one exemption 5 document that the State Department was attempting to withhold was found to be post-decisional. Further, the Department of Homeland Security's failure to establish a pending or prospective enforcement proceedings led the court to rule that it didn't establish that exemption 7(A) applied to 86 pages of material. The court further found that State and Homeland Security did not adequately explain why it couldn't segregate information on the withheld pages.
The agencies will now attempt to further explain segregability and Homeland Security will take another crack at justifying its use of exemption 7(A).