Legg v. Washington Metropolitan Area Transit Authority
Civil Action No. 2016-1023
D.D.C.Jun 9, 2017Background
- Plaintiff Ronald L. Legg, proceeding pro se, sued WMATA and WMATA Assistant General Counsel under FOIA seeking records about a third-party individual.
- Defendants moved to dismiss under Rule 12(b)(1) (lack of subject-matter jurisdiction) and Rule 12(b)(6) (failure to state a claim).
- Defendants argued WMATA is not a federal "agency" under FOIA and that Plaintiff failed to exhaust WMATA’s administrative Public Access to Records Policy (PARP).
- The district court analyzed FOIA’s definition of "agency" and WMATA’s interstate-compact status and found no authority treating WMATA as an executive-branch agency covered by FOIA.
- The court concluded it lacked subject-matter jurisdiction over the FOIA claim and dismissed the case without prejudice, noting Plaintiff’s potential recourse under WMATA’s PARP.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether WMATA is an "agency" subject to FOIA | FOIA request seeks records from WMATA; FOIA applies | WMATA is an interstate-compact authority, not an executive-branch agency covered by FOIA | WMATA is not shown to be an FOIA "agency"; FOIA jurisdiction lacking |
| Whether court has subject-matter jurisdiction over the FOIA claim | Court should hear FOIA suit to compel records | Court lacks jurisdiction because FOIA applies only to federal agencies | Court lacks subject-matter jurisdiction and must dismiss |
| Whether Plaintiff exhausted administrative remedies under WMATA’s PARP | Plaintiff made a request (implicit: should be adjudicated) | Plaintiff did not perfect the request or obtain a final administrative decision under PARP | Court noted exhaustion was not shown and PARP is the proper avenue |
| Effect of dismissal on Plaintiff's remedies | Dismissal should not preclude further action | Dismissal without prejudice is appropriate | Case dismissed without prejudice; Plaintiff may pursue PARP remedies |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (federal courts are courts of limited jurisdiction)
- Gonzalez v. Thaler, 132 S. Ct. 641 (subject-matter jurisdiction cannot be waived)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (plaintiff bears burden to establish jurisdiction)
- Kissinger v. Reporters Comm. for Freedom of the Press, 445 U.S. 136 (FOIA jurisdiction requires an agency withholding agency records)
- McGehee v. CIA, 697 F.2d 1095 (D.C. Cir.) (three-component test for FOIA jurisdiction)
- Judicial Watch, Inc. v. U.S. Secret Serv., 726 F.3d 208 (D.C. Cir.) (definition of FOIA "agency")
- KiSKA Const. Corp.-U.S.A. v. Washington Metro. Area Transit Auth., 167 F.3d 608 (D.C. Cir.) (describing WMATA’s interstate-compact status)
- Pratt v. Webster, 673 F.2d 408 (D.C. Cir.) (FOIA as statutory right of public access)