Sai v. TSA, No. 14-0403, 2014 WL 3029217 (D.D.C. July 7, 2014) (Huvelle, J.)

Sai v. TSA, No. 14-0403, 2014 WL 3029217 (D.D.C. July 7, 2014) (Huvelle, J.)

Re: Request for records concerning alleged discrimination against plaintiff

Disposition: Denying plaintiff's motion for preliminary injunction

• Litigation Considerations, Preliminary Injunctions:  The court "den[ies] plaintiff's motion for a preliminary injunction."  The court relates that plaintiff "seeks only TSA's 'responses to [his] Rehabilitation Act grievances . . . regardless of their state of 'review' or composition.'"  The court holds that, while "[c]ourts have on occasion issued preliminary injunctions requiring an agency's expedited release of responsive documents under FOIA," "[e]ven considering the narrowness of plaintiff's requested relief . . . the Court concludes that plaintiff is not entitled to a preliminary injunction because he has failed to demonstrate any—let alone 'very serious'—irreparable harm that would befall him absent the extraordinary relief of a preliminary injunction."  The court rejects plaintiff's contention that "any delay is 'per se' irreparable harm."  The court therefore finds that "plaintiff 'has failed to demonstrate any time sensitive need for [the requested] information that will be irreparably lost if disclosure does not occur immediately' and this case is allowed to proceed down the typical path of FOIA litigation."