Klayman v. Clinton, No. 15-14080, 2016 WL 4271869 (11th Cir. Aug. 15, 2016) (per curiam)

Klayman v. Clinton, No. 15-14080, 2016 WL 4271869 (11th Cir. Aug. 15, 2016) (per curiam)

Re: Requester's assertion that responsive documents were misappropriated

Disposition: Affirming district court's dismissal of requester's amended complaint

• Litigation Considerations, Standing: The Court of Appeals for the Eleventh Circuit "agree[s] with the district court that [the requester] failed to allege facts sufficient to support Article III standing" because "[the requester] has no general property interest in government records and FOIA does not provide for 'private actions to recover records wrongfully removed from Government custody.'" The court relates that the "claims [at issue] arose out of two requests for public documents lodged with the United States Department of State pursuant to the [FOIA]." "[The requester] alleged, among other facts, that the State Department failed to respond adequately because the defendants . . . misappropriated responsive documents."