Willaman v. Erie ATF, No. 15-1566, 2015 WL 5023588 (3rd Cir. Aug. 25, 2015) (per curiam)

Willaman v. Erie ATF, No. 15-1566, 2015 WL 5023588 (3rd Cir. Aug. 25, 2015) (per curiam)

Re: Plaintiff's attempt to compel ATF to answer questions pertaining to processing of applications for relief from firearms disabilities

Disposition: Affirming district court's dismissal of plaintiff's claim

• Procedural Requirements, Proper FOIA Requests:  The Court of Appeals for the Third Circuit holds that "[t]o the extent that [plaintiff] sought relief under the FOIA, the ATF properly concluded that his request did not 'reasonably describe[ ]' the records sought."  "Instead, [plaintiff] requested that the ATF explain why an individual could not pay for the processing of an application under § 925(c)."  "It is clear, however, 'that nothing in the [ FOIA] requires 'answers to interrogatories' but rather and only disclosure of documentary matters which are not exempt.'"