Between 2016 and 2020, journalist and transparency activist Emma Best filed more than 6,000 Freedom of Information Act requests, including more than 1,600 directed to the FBI. Best published hundreds of articles based on government records and pursued files involving intelligence agencies, historical hacking incidents, the Church of Scientology, and the Senate Church Committee. The Calyx Institute described Best as consistently ranking at or near the FBI’s list of “vexsome” FOIA requesters. In 2016, the bureau investigated Best and considered prosecution over their use of the records-access process.
In 2021, the FBI banned Best from filing further FOIA requests and closed their existing requests. Best challenged the action with assistance from national-security attorneys Mark Zaid and Brad Moss; after several months, the ban was lifted and the requests were reopened. The episode illustrated how an agency responsible for disclosure could use administrative controls to obstruct an unusually persistent requester, while also showing that legal representation could restore access to the statutory process. The source does not report a criminal charge or final judicial ruling against Best.