Bayala v. DHS, No. 14-00007, 2014 WL 5573326 (D.D.C. Nov. 4, 2014) (Contreras, J.)
Re: Request for records concerning plaintiff's request for asylum
Disposition: Granting defendant's motion for summary judgment; denying plaintiff's motion for summary judgment
- Litigation Considerations, Exhaustion of Administrative Remedies: The court holds that "DHS has complied with its statutory obligations, and [plaintiff] must do likewise by exhausting administrative remedies before seeking judicial review." The court explains that "Congress has required FOIA requesters to exhaust this process, so long as the agency's initial response contains 'reasons' and meets other basic requirements." "If [plaintiff] was unhappy with the reasons proffered by DHS, he could have registered this complaint in an administrative appeal rather than filing this action prematurely."