Risenhoover v. U.S. Dep’t of State, No. 21-2563, 2023 WL 2043218 (D.D.C. Feb. 16, 2023) (Howell, C.J.)

Risenhoover v. U.S. Dep’t of State, No. 21-2563, 2023 WL 2043218 (D.D.C. Feb. 16, 2023) (Howell, C.J.)

Re:  Unclear request for records

Disposition:  Granting defendants’ motion for summary judgment

• Procedural Requirements, Proper FOIA Requests:  The court relates that “[g]iven the incoherency of plaintiff’s 103-page FOIA Request, . . . defendants’ ‘multiple experienced FOIA processing professionals’ could not ‘discern which records Plaintiff was seeking or how to approach a search for responsive records’ . . . .”  “While agencies have ‘a duty to construe a FOIA request liberally,’ . . . they are not obligated to search ‘beyond “the four corners of the request,” nor are they “required to divine a requester’s intent.”’”  “Defendants made efforts to confer with plaintiff to understand better what records were sought within the sprawling ‘four corners of the request,’ but without success.”  “This record showing defendants’ ‘multiple good faith efforts’ to have plaintiff clarify or narrow his request . . . evinces no improper withholding under FOIA.”