Equity estoppel, or “matter preclusion,” also may foreclose after that thought out of a good FOIA match Payne Companies v. United states, (207) however, the Court of Appeals for the District of Columbia Circuit held that when records are routinely withheld at the initial processing level, but consistently released after an administrative appeal, and when… Continue reading Equity estoppel, or “matter preclusion,” also may foreclose after that thought out of a good FOIA match