Wednesday, May 13, 2015
Manna v. DOJ, No. 13-313, 2015 WL 2264866 (D.D.C. May 13, 2015) (Moss, J.)
Re: Request for videotape concerning plaintiff's litigation
Disposition: Granting defendant's motion for summary judgment
- Litigation Considerations, Mootness and Other Grounds for Dismissal: The court holds that "[b]ecause Plaintiff has obtained the relief sought in [his] request, this controversy is moot." The court finds that "[p]laintiff does not dispute that he received the surveillance videotape he requested in his May 2012 FOIA request." Additionally, the court finds that "[t]o the extent that Plaintiff contends that his May 2012 request sought materials in addition to the videotape, that is not a fair construction of the request." "The surveillance video was the only material requested and 'reasonably describe[d]' in Plaintiff's May 2012 FOIA request." Finally, the court finds that "[p]laintiff never moved to amend his complaint to add claims based on other requests, and he cannot expand the scope of this litigation by merely referring to other requests in his opposition to Defendants' motion."
Updated June 26, 2015