Skip to main content

Satterlee v. IRS, No. 21-03046, 2021 WL 2584384 (W.D. Mo. June 23, 2021) (Ketchmark, J.)


Satterlee v. IRS, No. 21-03046, 2021 WL 2584384 (W.D. Mo. June 23, 2021) (Ketchmark, J.)

Re:  Plaintiff's "alleged[ly] unanswered FOIA requests"

Disposition:  Denying defendant's motion to dismiss

  • Procedural Requirements, Proper FOIA Requests:  The court relates that, previously, "[t]he Court held Plaintiff failed to exhaust his administrative remedies – a prerequisite to bringing an action under FOIA – determining Plaintiff did not carry his burden of proving Defendant received his FOIA requests."  "Plaintiff now alleges he resubmitted his FOIA requests . . . ."  "Plaintiff provides evidence purportedly showing Defendant received his FOIA requests in the form of certified mail receipts."  "The receipts are allegedly signed by employees of Defendant, and USPS tracking logs claim the packages were delivered to an address in Washington D.C., 20220 – the zip code where Defendant receives FOIA requests."  "Defendant claims to have no record of either request."  The court finds that "Plaintiff provided sufficient evidence to demonstrate Defendant received both mailed requests."  "Plaintiff's proffered evidence is sufficient to satisfy the Court at this time he exhausted his administrative remedies."

    Separately, the court relates that "Defendant contends the November Request does not ask for 'records,' rather the Request is a demand to cease debt collection against Plaintiff until Defendant produces the requested documents."  The court finds that "[c]ourts construe FOIA requests liberally in favor of disclosure."  "That mandate includes construing otherwise invalid questions or demands for action as valid when they request documents."  The court finds that "[w]hen construing the November Request liberally, it contains the same valid request [at issue in an earlier request to which defendant did not object]."
Court Decision Topic(s)
District Court opinions
Procedural Requirements, Proper FOIA Requests
Updated July 14, 2021