Pondexter v. Secretary of HUD, No. 19-1576, 2019 WL 4454408 (3d Cir. Sept. 17, 2019) (per curiam)

Pondexter v. Secretary of HUD, No. 19-1576, 2019 WL 4454408 (3d Cir. Sept. 17, 2019) (per curiam)

Re:  Request for records concerning requester's housing discrimination claim

Disposition:  Summarily affirming of district court's dismissal of requester's complaint

• Litigation Considerations, Pleadings:  The Court of Appeals for the Third Circuit holds that "[t]here are multiple threshold deficiencies with these claims as well, including that FOIA claims may not be brought against the individual defendants here, . . . and that [the requester] sought only money damages, which are not available under FOIA . . . ."  Additionally, the court notes that "[the requester] did not plausibly allege that any specific agency records have been improperly withheld."  "Nor does it appear that he could, as [the requester] did not dispute the representations from HUD – in a letter attached to his complaint – that HUD had fully granted his FOIA request and had provided him with all documents responsive to his FOIA request."