Drew v. Murphy, No. 24-1116, 2024 WL 2286203 (7th Cir. May 21, 2024) (per curiam)

Drew v. Murphy, No. 24-1116, 2024 WL 2286203 (7th Cir. May 21, 2024) (per curiam)

Re:  Request for records concerning grounds for requester’s enrollment in drug education course

Disposition:  Affirming district court’s dismissal of requester’s complaint at screening based on failure to state a claim

• Litigation Considerations, Pleadings:  The Cout of Appeals for the Seventh Circuit holds that “[t]he district court correctly dismissed [the requester’s FOIA claim] because the Act does not create a cause of action against individual federal employees.”  “Regardless, his allegation that the [government] ‘effectively denied’ his document request is inaccurate according to his own amended complaint.”  “Though [the requester] had yet to receive documents from the Bureau of Prisons’ Central Office when he filed suit, relief is warranted only when an agency improperly withholds documents.”  “And here, the Bureau notified [the requester] that it assigned his request to the ‘complex track,’ placed it in chronological order according to the date of receipt, and must work through a COVID-era backlog of requests.”  “Nothing in the Bureau’s reply suggests that it has improperly withheld [the requester’s] requested documents.”