U.S. v. Whitfield, No. 18-5718, 2019 U.S. App. LEXIS 578 (6th Cir. Jan. 8, 2019) (per curiam)

U.S. v. Whitfield, No. 18-5718, 2019 U.S. App. LEXIS 578 (6th Cir. Jan. 8, 2019) (per curiam)

Re:  Request for records concerning requester's criminal prosecution

Disposition:  Affirming district court's denial of requester's motion to compel

• Litigation Considerations, Jurisdiction:  "Based on the plain language of § 552(a)(4)(B) and the foregoing persuasive authority, [the Court of Appeals for the Sixth Circuit] find[s] that a party must file a complaint in a separate civil action in order to challenge an adverse FOIA determination."  The requester had previously filed a motion to compel in a criminal case.