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Cromitie v. Trump, No. 19-02868, 2019 WL 6034952 (D.D.C. Nov. 13, 2019) (Chutkan, J.)

Date

Cromitie v. Trump, No. 19-02868, 2019 WL 6034952 (D.D.C. Nov. 13, 2019) (Chutkan, J.)

Re:  Requests for records concerning plaintiff's criminal case

Disposition:  Dismissing plaintiff's complaint

  • Litigation Considerations, Pleadings:  The court holds that "plaintiff has failed to state a viable claim under the FOIA."  The court finds that "Plaintiff does not allege that an agency has improperly withheld records responsive to a properly submitted FOIA request."  "The instant complaint neither references a FOIA request number nor contains any other information, e.g., a copy of the actual request(s) submitted."  "It is even unclear what specific document(s) plaintiff seeks."  Additionally, the court finds that "FOIA authorizes suit against federal agencies but does not create a right of action against individual employees of the agency."  "Plaintiff has sued only individual defendants, which is improper."  "In fact, it is unclear which agency, if any, allegedly fielded any FOIA request(s)."
Court Decision Topic(s)
District Court opinions
Litigation Considerations, Pleadings
Updated December 9, 2021