Wheeler v. Mahar, No. 17-1256, 2017 WL 4356893 (N.D. Ga. Oct. 2, 2017) (Duffey, Jr., J.)

Wheeler v. Mahar, No. 17-1256, 2017 WL 4356893 (N.D. Ga. Oct. 2, 2017) (Duffey, Jr., J.)

Re:  Requests for records concerning former President Barack Obama's private passport and other travel records

Disposition:  Granting defendant's motion to dismiss

• Procedural Requirements, Proper FOIA Requests & Litigation Considerations, Exhaustion of Administrative Remedies:  The court holds that "Plaintiff's failure to obtain and provide to the Department of State the required written authorization from former President Obama amounts to a failure to exhaust his administrative remedies, and Plaintiff is therefore, as a matter of law, not entitled to relief."