LaVictor v. Trump, No. 19-01900, 2020 WL 2527192 (D.D.C. May 18, 2020) (McFadden, J.)

LaVictor v. Trump, No. 19-01900, 2020 WL 2527192 (D.D.C. May 18, 2020) (McFadden, J.)

Re:  Requests for records concerning plaintiff's criminal case

Disposition:  Granting defendants' motion for summary judgment

• Litigation Considerations, Pleadings:  The court relates that "[t]he only proper defendant in a FOIA case is a federal agency."  "The Complaint lists no agencies as defendants; it names only the President, the Attorney General, and officials at four DOJ component agencies."  "So the Court will dismiss these officials as defendants and will construe the Complaint as a FOIA action against the four DOJ component agencies."
   
• Litigation Considerations, Exhaustion of Administrative Remedies:  The court relates that "[plaintiff] has not submitted a FOIA request to three of the agencies."  "For the fourth one, he sent a request four years ago but then never filed an administrative appeal after the agency responded."  The court finds that "[plaintiff] thus failed to exhaust his administrative remedies."