Barnes v. Trump, No. 20-0605, 2020 U.S. Dist. LEXIS 41248 (D.D.C. Mar. 6, 2020) (McFadden, J.)

Barnes v. Trump, No. 20-0605, 2020 U.S. Dist. LEXIS 41248 (D.D.C. Mar. 6, 2020) (McFadden, J.)

Re:  Request for "'documents necessary for any criminal defense'"

Disposition:  Dismissing plaintiff's complaint

• Litigation Considerations, Pleadings:  The court holds that "FOIA 'only authorizes suits against certain executive branch "agencies," not individuals.'"  Additionally, "[a]part from naming the wrong defendants, [the court finds that] plaintiff does not allege that an agency has improperly withheld records responsive to a properly submitted FOIA request."
   
• Procedural Requirements, Entities Subject to the FOIA:  The court notes that "plaintiff appears to have requested documents only from the United States District Court for the Eastern District of Michigan."  The court finds that "FOIA 'adopts the definition of agency contained in 5 U.S.C. § 552 (a)(1)(B), which specifically excludes from its coverage "the courts of the United States."'"