Between 2016 and 2020, transparency activist and reporter Emma Best filed more than 6,000 Freedom of Information Act requests, including more than 1,600 directed to the FBI and numerous others to U.S. intelligence agencies. Best published hundreds of articles based on records requests and helped place a CIA database containing roughly 13 million pages of declassified files online in 2017. The FBI investigated Best in 2016 and considered prosecution over their use of FOIA; the Calyx Institute later described Best as consistently ranking near the bureau’s top “vexsome FOIA requesters.” These actions illustrate how an openness mechanism intended to expose surveillance and national-security activity became a point of conflict with the agency responsible for withholding such records.
In 2021, the FBI banned Best from submitting additional FOIA requests and closed their existing requests. With assistance from national-security attorneys Mark Zaid and Brad Moss, Best challenged the restriction, and the ban was lifted after several months, with the requests reopened. The source does not establish that the FBI was formally sanctioned or that the restriction violated a court ruling, but the episode demonstrates the practical power an agency can exert over persistent oversight requesters through administrative access controls rather than public litigation.