Sai v. TSA, No. 14-0403, 2014 WL 3029217 (D.D.C. July 7, 2014) (Huvelle, J.)

Monday, July 7, 2014

Sai v. TSA, No. 14-0403, 2014 WL 3029217 (D.D.C. July 7, 2014) (Huvelle, J.)

Re: Request for records concerning alleged discrimination against plaintiff

Disposition: Denying plaintiff's motion for preliminary injunction

  • Litigation Considerations, Preliminary Injunctions:  The court "den[ies] plaintiff's motion for a preliminary injunction."  The court relates that plaintiff "seeks only TSA's 'responses to [his] Rehabilitation Act grievances . . . regardless of their state of 'review' or composition.'"  The court holds that, while "[c]ourts have on occasion issued preliminary injunctions requiring an agency's expedited release of responsive documents under FOIA," "[e]ven considering the narrowness of plaintiff's requested relief . . . the Court concludes that plaintiff is not entitled to a preliminary injunction because he has failed to demonstrate any—let alone 'very serious'—irreparable harm that would befall him absent the extraordinary relief of a preliminary injunction."  The court rejects plaintiff's contention that "any delay is 'per se' irreparable harm."  The court therefore finds that "plaintiff 'has failed to demonstrate any time sensitive need for [the requested] information that will be irreparably lost if disclosure does not occur immediately' and this case is allowed to proceed down the typical path of FOIA litigation."


District Court
Litigation Considerations
Updated October 6, 2014