Reynolds v. DOJ, No. 16-1428, 2017 WL 1495932 (D.D.C. Apr. 26, 2017) (Boasberg, J.)
Date
Reynolds v. DOJ, No. 16-1428, 2017 WL 1495932 (D.D.C. Apr. 26, 2017) (Boasberg, J.)
Re: Requests for records concerning search of plaintiff's home and plaintiff's arrest
Disposition: Granting defendant's motion for summary judgment
- Procedural Requirements, Proper FOIA Requests: The court relates that "DOJ has offered comprehensive sworn testimony that it never received Plaintiff's FOIA requests." "[Plaintiff] rejoins by attaching copies of his two letters and swearing he mailed them, but this evidence does not show that they were ever received by Justice." The court explains that, "[i]n other words, Plaintiff does not offer proof via, e.g., a certified-mail receipt or any other form of mailing that his missives reached their intended target." The court finds that "[a]s DOJ did not receive [plaintiff's] correspondence, it had no obligation to search for or produce records." "Absent receipt of the request, the agency 'has no obligation to respond to it.'" Also, responding to "[p]laintiff['s] argu[ment] that DOJ should now look for his documents since it cannot dispute that it is currently aware of his request[,]" the court finds that "[w]ere the Court to acquiesce, such a procedure would unwisely bypass the administrative process."
Court Decision Topic(s)
District Court opinions
Procedural Requirements, Proper FOIA Requests
Updated December 14, 2021