Scott v. DHS, No. 24-00508, 2024 WL 3338859 (D.D.C. July 9, 2024) (McFadden, J.)

Scott v. DHS, No. 24-00508, 2024 WL 3338859 (D.D.C. July 9, 2024) (McFadden, J.)

Re:  Plaintiff’s alleged FOIA request

Disposition:  Granting defendant’s motion to dismiss; denying plaintiff’s FOIA complaint

• Litigation Considerations, Pleadings:  The court finds that “[plaintiff] alleges no facts at all in support of a claim under FOIA.”  “From [plaintiff’s complaint], the Court can glean that the Government refused to give him something related to FOIA, but it is unclear what.”  “To be sure, his filings include a copy of a letter from the Department of Justice regarding a FOIA request he submitted.”  “But he alleges no facts and attaches no exhibits that would enable the Court to determine when he made that request, or what he made it for.”  “Indeed, although the Department of Justice responded to his FOIA request, it is not even clear which part of the Department he submitted his request to.”  “So the Court has no way of knowing whether the Government’s alleged failure ‘to supply a copy . . . of [his] foia’ is legally actionable.”  “To state just one obvious problem, [plaintiff] never says when he submitted his FOIA request.”  “So the Court cannot even tell whether the Government had an obligation to produce any documents for him by the time he filed this lawsuit.”  “Under these circumstances, [plaintiff] has failed to allege sufficient facts to give rise to ‘the reasonable inference that the defendant is liable for the misconduct alleged.’”