> Only if there's an active law enforcement investigation the FOIA request touches.

Right, but that doesn't mean that the named entity is either the target or even a subject of the investigation. Because the FOIA request is for all documents relating to the entity, if there is even one document related to any investigation of anything that mentions the named entity in any capacity, it is going to be withheld for that reason.

I don’t think that your comment acknowledges the reality that FOIA responses are decided by RNG unless you sue.