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Cunningham v. O'Neill, No. 13-960, 2013 WL 3753554 (D.D.C. July 17, 2013) (Collyer, J.)

Re: Request for records relating to plaintiff's prior civil rights suit against Deputy United States Marshals and city police detective Disposition: Granting defendant's motion to dismiss
  • Litigation Considerations:  The court finds that, "[plaintiff] cannot possibly prevail here because he has sued individual federal officials under FOIA and FOIA authorizes relief only against covered federal agencies."  The court notes that, "in FOIA cases individual federal employees are not proper parties."  The court notes that, "many of the federal officials who are Defendants here are not employed in the executive branch . . . ."  The court concludes that, "FOIA covers only agencies in the executive branch of government."
Court Decision Topic(s)
District Court opinions
Litigation Considerations, Supplemental to Main Categories
Updated August 6, 2014