Jenkins v. United States Department of Justice, 263 F. Supp. 3d 231

Background

Van Jenkins, a Michigan inmate, submitted FOIA requests seeking bond/judgment information and case records he identified by state-court case numbers.
His requests reached the Executive Office for United States Attorneys (EOUSA), which determined the requests were deficient because they did not identify the specific U.S. Attorney’s Office(s) to be searched and lacked required identity verification.
EOUSA concluded DOJ was not involved in the cited Michigan state prosecutions and that DOJ systems were unlikely to contain responsive records; it assigned tracking numbers and asked Jenkins to file corrected requests.
Jenkins filed an administrative appeal to the DOJ Office of Information Policy seeking expedited processing but did not provide the corrections EOUSA requested; DOJ received no further compliant submissions.
The Court considered (1) whether Jenkins submitted a proper FOIA request, (2) whether EOUSA had to search for records, and (3) an APA claim alleging unlawful agency delay.
The Court granted summary judgment for defendant, holding EOUSA complied with FOIA, no search was required given the unlikelihood of responsive records, and the APA claim was precluded by FOIA remedies.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jenkins submitted a proper FOIA request to EOUSA	Jenkins contends his submission to the U.S. Attorney’s Office for the Eastern District of Michigan put DOJ on notice of the records sought	EOUSA argues Jenkins failed to reasonably describe records and did not identify specific USAO(s) as required, rendering the request defective	Court: Request was not proper; EOUSA properly notified Jenkins of deficiencies and was not obligated to process further until corrected
Whether EOUSA had an obligation to search for or possess responsive records	Jenkins argues case numbers and his statements show responsive records must exist within federal systems	EOUSA argues DOJ did not prosecute the cited state cases and DOJ systems were unlikely to contain the requested state-court records, so a search would be futile/burdensome	Court: EOUSA need not search; agency sufficiently showed unlikelihood of responsive records and that a burdensome nationwide search was not required
Whether agency delay supports an APA claim	Jenkins asserts EOUSA’s handling and failure to process his FOIA request and expedited-processing plea violated the APA	DOJ contends FOIA provides the exclusive remedy for alleged failures to process FOIA requests	Court: APA claim dismissed because FOIA provides an adequate remedy and precludes APA relief for FOIA processing complaints
Motions for counsel and injunctive relief filed by Jenkins	Jenkins sought appointment of counsel (for appeal) and injunctive relief/TRO	DOJ argued those requests were inappropriate in this FOIA action and outside this Court’s jurisdiction for conditions of confinement	Court: Granted leave to file but denied both—appointment of counsel for appeal must be sought to the D.C. Circuit; injunction/TRO claims unrelated to this FOIA matter and not for this forum

Key Cases Cited

Armstrong v. Bush, 139 F.R.D. 547 (D.D.C. 1991) (reasonably descriptive standard for FOIA requests)
Oglesby v. U.S. Dep't of the Army, 920 F.2d 57 (D.C. Cir. 1990) (agency must make a good-faith search using methods reasonably expected to produce requested records)
Goland v. CIA, 607 F.2d 339 (D.C. Cir. 1978) (agency need not honor requests that impose unreasonably burdensome searches)
Earle v. U.S. Dep’t of Justice, 217 F. Supp. 3d 117 (D.D.C. 2016) (summary judgment for DOJ where declarations showed documents did not exist and search would be futile)
Elec. Privacy Info. Ctr. v. Nat'l Sec. Agency, 795 F. Supp. 2d 85 (D.D.C. 2011) (APA review and FOIA interplay; remedies under FOIA)
Feinman v. FBI, 713 F. Supp. 2d 70 (D.D.C. 2010) (courts decline jurisdiction over APA claims seeking FOIA remedies)