that an agency invoking Exemption 7 show that the investigatory activity that gave rise to the documents is “related to the enforcement of federal laws” and there is a “rational nexus” between the investigation at issue and the agency’s law enforcement duties. Pratt, 673 F.2d at 420-21. But, that court did not require such a showing when considering requests for non-investigatory materials, instead holding that IRS “internal agency material relating to guidelines, techniques, and procedures for law enforcement investigations and prosecutions outside of the context of a specific investigation” facially meet the Exemption 7 threshold and require further analysis under Exemption 7(E). Tax Analysts, 294 F.3d at 78. See Sack v. U.S. Def't of Def., 823 F.3d 687, 693-94 (D.C. Cir. 2016) (<HOLDING>); Morley v. CIA, 508 F.3d 1108, 1128-29 (D.C.
holding reports on the efficacy of polygraph examinations were compiled for law enforcement purposes holding that expert reports were not required to mention the defendant hospital because reports were based upon the actions of hospital physicians holding that records pertaining to the investigation of an inmateoninmate assault were compiled for law enforcement purposes because they were created in connection with the bops responsibility to protect  inmates staff and the community internal quotation marks and citations omitted holding that records concerning polygraph examination procedures and other law enforcement techniques are protected from disclosure under  exemption 7e holding that exemption b7c covers investigatory records compiled for law enforcement purposes to the extent that they constitute an unwarranted invasion of personal privacy and protects the identities of investigative agents