Leytman v. United States, No. 19-3929, 2020 WL 6297440 (2d Cir. Oct. 28, 2020) (per curiam)

Leytman v. United States, No. 19-3929, 2020 WL 6297440 (2d Cir. Oct. 28, 2020) (per curiam)

Re:  Requests for records concerning plaintiff

Disposition:  Vacating district court's dismissal of requester's FOIA claim; remanding with instructions to rule on FOIA claim

• Litigation Considerations:  The Court of Appeals for the Second Circuit holds that "[o]n remand, the district court also should address [the requester's] FOIA claim."  "Before the district court, [the requester] twice complained that TSA violated FOIA by failing to fully disclose requested materials."  "Neither the district court's order dismissing [the requester's] first complaint nor its order dismissing [the requester's] amended complaint specifically mentioned these allegations."  "Thus, we do not know whether the district court intended to dismiss [the requester's] FOIA claim or, if it did, the grounds for that decision."