A Better Way for BPA v. DOE, No. 15-5896, 2016 U.S. Dist. LEXIS 36355 (W.D. Wash. Mar. 21, 2016) (Leighton, J.)
Re: Request for records concerning environmental impact statement for power line
Disposition: Granting defendant's motion to dismiss
- Litigation Considerations, Pleadings: The court holds that "[plaintiff] . . . lacks standing." The court relates that "[a]t issue is whether [the requester] adequately notified [defendant] that she was making a request on [plaintiff's] behalf." The court finds that "[the requester] offered no indication that she had the power to act as [plaintiff's] agent, and she did not state that her request was made on [plaintiff's] behalf." "[The requester's] passing mention of the 'organization' did not adequately identify that organization as the requester."