Biggins v. USPS, No. 22-6310, 2025 WL 660606 (D.N.J. Feb. 28, 2025) (Shipp, J.)

Biggins v. USPS, No. 22-6310, 2025 WL 660606 (D.N.J. Feb. 28, 2025) (Shipp, J.)

Re: Request for third party address

Disposition:  Granting defendant’s motion to dismiss

• Litigation Considerations, Exhaustion of Administrative Remedies; Procedural Requirements, Proper FOIA Requests:  “[T]he Court finds that Plaintiff has failed to exhaust administrative remedies because he failed to make proper FOIA requests.”  “First and foremost, the At-Issue Requests seek to obtain information maintained by USPS rather than ‘agency records.’” “It is well-settled that FOIA ‘deals with “agency records,” not information in the abstract.’”  “Along the same lines, FOIA does not create an obligation for an agency ‘“to answer questions disguised as a FOIA request . . . or to create documents or opinions in response to an individual’s request for information.”’”  “Second, Plaintiff failed to comply with USPS’s policies and procedures for making FOIA requests.”  “To make a proper FOIA request in accordance with USPS’s policies and procedures, the ‘[FOIA] request must be submitted to the appropriate FOIA Requester Service Center ([‘]RSC[’]).’”  “Here, the At-Issue Requests were addressed and submitted to the Postmasters of the United States Post Offices in Princeton and Princeton Junction, New Jersey, which are not appropriate FOIA RSCs.” “Furthermore, Plaintiff also failed to correctly label the At-Issue Requests in accordance with USPS’s policies and procedures.”