Pickering-George v. U.S. Dist. Court, No. 12-3793, 2013 WL 1303792 (3rd Cir. Apr. 2, 2013) (per curiam)
- Proper Party Defendant: The Third Circuit finds that the district court properly dismissed plaintiff's claim for litigation costs under the FOIA. The FOIA does not apply to United States Courts and plaintiff "did not substantially prevail in his 2005 civil action and cannot claim relief on that basis."