Ortiz v. Yellen, No. 22-00998, 2022 WL 1556397 (D.D.C. May 11, 2022) (McFadden, J.
Ortiz v. Yellen, No. 22-00998, 2022 WL 1556397 (D.D.C. May 11, 2022) (McFadden, J.)
Re: Plaintiff's correspondence, which "seemingly attempted to compel the Federal Reserve to issue him a payment"
Disposition: Dismissing plaintiff's complaint without prejudice
- Procedural Requirements, Proper FOIA Requests: "'An agency's obligation to disclose records is not triggered, however, until a proper request has been received.'" "A proper request shall reasonably describe the requested records and be made in accordance with published rules stating the time, place, fees (if any), and procedures to be followed." "Here, there is no indicia that an agency owed plaintiff an obligation under the FOIA." "The complaint is devoid of any details regarding the FOIA request sufficient enough to satisfy a colorable claim, including, the actual content of the request, the information sought, the specific address or custodian to whom the FOIA request was directed, or any other enlightening information, e.g, a copy of the actual request submitted." "And it appears plaintiff’s 'FOIA request' was not, in fact, one for records." "Instead, plaintiff seemingly attempted to compel the Federal Reserve to issue him a payment, which is relief that falls well outside of the limited parameters of the FOIA."
- Litigation Considerations, Pleadings: "[P]laintiff has sued an individual defendant, but the FOIA authorizes suit against federal agencies only and does not create a right of action against individual officials or employees of an agency."