Hall v. DOJ, No. 16-1591, 2017 WL 4174419 (D.D.C. Sept. 19, 2017) (Contreras, J.)

Hall v. DOJ, No. 16-1591, 2017 WL 4174419 (D.D.C. Sept. 19, 2017) (Contreras, J.)

Re:  Requests for records concerning plaintiff, as well as for all phone records maintained by BOP

Disposition:  Granting three defendants' motions for summary judgment; granting one defendant's motion to dismiss; denying one defendant's motion for summary judgment

• Procedural Requirements, Proper FOIA Requests:  Regarding "[plaintiff's] sweeping FOIA request for 'all phone records in [BOP's] possession[,]'" the court holds that "BOP's description of its massive telephone systems . . . shows why that request was simply too broad 'to enable[ ] a professional employee of the agency who was familiar with the subject area of the request to locate the record with a reasonable amount of effort.'"
   
• Litigation Considerations, Exhaustion of Administrative Remedies:  "Because neither party has acknowledged the Certification of Identity or addressed its implications nor have they addressed the outcome of the re-routed request, the Court is not in a position to fully assess EOUSA's failure to exhaust arguments."  "Thus, as to this aspect of the complaint, the Court will deny EOUSA's motion without prejudice to reconsideration of a renewed motion that addresses the significance, if any, of the Certification of Identity and what actions, if any, EOUSA took in response to the routed request and any appropriate relief."
   
• Litigation Considerations, Adequacy of Search:  "Plaintiff has not questioned ATF's search, and the Court is satisfied from the declarant's detailed description of the filing systems searched and the search methods employed that ATF conducted a search reasonably calculated to locate responsive records."  Similarly, "[p]laintiff has not questioned the [Criminal Division's] search, and the Court is satisfied from the declarant's description that the Criminal Division's search was reasonably calculated to locate potentially responsive records based on the information provided in the FOIA request."  Finally, the court holds that "DEA, having satisfied its FOIA obligations, is too entitled to judgment as a matter of law."