Kaplan v. Ebert, No. 15-3578, 2016 WL 2342065 (3rd Cir. May 3, 2016) (per curiam)

Kaplan v. Ebert, No. 15-3578, 2016 WL 2342065 (3rd Cir. May 3, 2016) (per curiam)

Re: Request for records concerning appellant and a third party

Disposition: Affirming district court's grant of summary judgment to agency

• Litigation Considerations, Pleadings:  The Court of Appeals for the Third Circuit holds that "[requester's] FOIA claims were not cognizable for two reasons."  "First, those claims may not be brought against federal officials/employees."  "Second, money damages – the relief that [requester] sought here – are not available under FOIA."