Jemerigbe v. Trump, No. 19-3167, 2019 U.S. Dist. LEXIS 191891 (D.D.C. Oct. 31, 2019) (Cooper, J.)

Jemerigbe v. Trump, No. 19-3167, 2019 U.S. Dist. LEXIS 191891 (D.D.C. Oct. 31, 2019) (Cooper, J.)

Re:  Claim that "defendants 'are legally responsible for withholding documents necessary for any criminal defense'"

Disposition:  Dismissing plaintiff's complaint

• Litigation Considerations, Jurisdiction & Pleadings; Procedural Requirements, Entities Subject to the FOIA:  "[T]he Court finds that plaintiff has stated no viable claim under the FOIA."  The court explains that "the FOIA 'only authorizes suits against certain executive branch "agencies," not individuals.'"  "Apart from naming the wrong defendants, plaintiff does not allege that an agency has improperly withheld records responsive to a properly submitted FOIA request."  "Rather, plaintiff alleges that he requested documents from a federal court."  "But the FOIA 'adopts the definition of agency contained in 5 U.S.C. § 551(1)(B), which specifically excludes from its coverage "the courts of the United States."'"