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Boyd v. Trump, No. 19-1664, 2020 WL 4597121 (D.D.C. Aug. 11, 2020) (Jackson, J.)

Date

Boyd v. Trump, No. 19-1664, 2020 WL 4597121 (D.D.C. Aug. 11, 2020) (Jackson, J.)

Re:  Plaintiff's multiple FOIA requests for information concerning himself

Disposition:  Granting defendant's motion for summary judgment

  • Procedural Requirements, Entities Subject to the FOIA:  The court relates that "[t]he only alleged recipient of a FOIA request from plaintiff is the United States District Court for the Eastern District of North Carolina submitted by motion filed in plaintiff's criminal case."  The court notes that "FOIA 'adopts the definition of agency contained in 5 U.S.C. § 551(a)(1)(b), which specifically excludes from its coverage "the courts of the United States."'"  "Therefore, to the extent plaintiff intends to bring a FOIA claim against a federal court or court employees, the claim must also be dismissed."
     
  • Litigation Considerations, Pleadings & Procedural Requirements, Proper FOIA Requests:  The court holds that "Plaintiff cannot obtain any relief under FOIA as against [the] individual defendants."  However, "[b]ecause the named defendants are government officials affiliated with DOJ and four component entities, the Court construes the complaint as raising FOIA claims against DOJ, EOUSA, OIP, USMS, and BOP."  Separately, the court holds that "to bring a lawsuit under FOIA, it was incumbent upon plaintiff to identify the agency to which he transmitted a request."  "Here, plaintiff does not allege he submitted a FOIA request to DOJ, OIP, USMS or BOP."  "[C]onsequently, the complaint fails to state a viable FOIA claim against DOJ, OIP, USMS an[d] BOP."  Regarding EOUSA, the court holds that "Plaintiff must show that he sent a proper FOIA request to the EOUSA in accordance with its procedures and that the EOUSA actually received his request."  "[T]he Court grants defendants’ motion for summary judgment based upon their showing that plaintiff did not submit a FOIA request to the EOUSA."
Court Decision Topic(s)
District Court opinions
Litigation Considerations, Pleadings
Procedural Requirements, Entities Subject to the FOIA
Procedural Requirements, Proper FOIA Requests
Updated September 11, 2020