Miles v. Department of Justice
201 F. Supp. 3d 185
D.D.C.2016Background
- Pro se federal prisoner Harry Edwin Miles mailed identical FOIA requests to five DOJ components seeking paper records relating to H.R. 3190/Public Law 80-772 between Jan. 2008 and Jul. 2009.
- DOJ components (Office of Information Policy, Office of the Solicitor General, Bureau of Prisons, and others) searched and returned "no responsive records" letters.
- Defendants moved for summary judgment under Fed. R. Civ. P. 56; the Court notified Miles of the response deadline and warned of consequences for not responding.
- Miles did not file an opposition or request extension; defendants submitted detailed declarations describing their search methods and results.
- Declarations established that searches were reasonably calculated to locate records; one email appearing responsive was identified as fraudulent and produced with an explanation.
- The Court granted summary judgment for defendants and dismissed overlapping APA claims as barred because FOIA provides an adequate remedy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of agency searches | Miles contends DOJ failed to produce requested records | DOJ contends it performed good-faith searches using reasonable methods and located no responsive records | Court: Searches were adequate; summary judgment for defendants |
| Failure to respond to motion | N/A (no opposition filed) | Defendants noted plaintiff's failure to oppose and cited Local Rule consequences | Court considered failure but independently reviewed declarations; ruled on merits anyway |
| Handling of potentially responsive email | Miles implied records existed (including an email) | DOJ produced the email and a memo showing it was fraudulent and not a genuine responsive record | Court accepted DOJ's explanation and attachments as satisfactory |
| APA claims duplicative of FOIA relief | Miles asserted APA causes of action based on same conduct | Defendants argued FOIA supplies adequate remedy, so APA claims are barred | Court dismissed APA claims as barred and granted summary judgment on FOIA claim |
Key Cases Cited
- Military Audit Project v. Casey, 656 F.2d 724 (D.C. Cir.) (affidavits may support FOIA summary judgment if detailed and uncontroverted)
- Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir.) (requirements for justifying nondisclosure with specific detail)
- Oglesby v. United States Dep't of the Army, 920 F.2d 57 (D.C. Cir.) (agency must make good-faith effort using methods reasonably expected to produce requested information)
- Neal v. Kelly, 963 F.2d 453 (D.C. Cir.) (notice to pro se litigant about consequences of failing to oppose summary judgment)
- Maydak v. U.S. Dep't of Justice, 254 F. Supp. 2d 23 (D.D.C.) (inadequate search may constitute improper withholding under FOIA)