Riddick v. United States Department of Justice
134 F. Supp. 3d 281
D.D.C.2015Background
- Riddick, proceeding pro se, seeks FOIA records from EOUSA, a DOJ component.
- Court analyzes cross-motions for summary judgment and a motion to strike a declaration.
- Riddick challenges EOUSA's processing and withholding under FOIA exemptions.
- Requests 12-3487, 12-3536, and 13-2508 involve searches, fees, and produced/redacted records.
- EOUSA relied on (b)(5) exemptions and fee-based closing; Riddick did not pay processing fees.
- Court denies Riddick’s summary judgment motion and grants EOUSA’s; motions to strike denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether EOUSA properly processed Riddick’s FOIA requests | Riddick asserts improper withholding and incomplete production | EOUSA conducted adequate search and properly withheld under (b)(5) | Yes; proper processing shown under (b)(5) and fee-related closure. |
| Whether documents withheld were protected by FOIA exemption (b)(5) | Riddick contends more documents should be released | Redactions/withholdings justified as attorney work product and deliberative process | Yes; records properly withheld under (b)(5). |
| Whether closing the request for nonpayment of fees was proper | Riddick disputes fee-based closure | FOIA requires payment before continued processing; closure proper absent payment | Yes; EOUSA acted properly by closing for nonpayment. |
| Whether Riddick’s motion to strike the Luczynski Declaration should succeed | Declaration is in bad faith and lacks personal knowledge | Declaration supported by agency procedures; no bad faith shown | No; motion to strike denied. |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (summary judgment standard requires no genuine issue of material fact when appropriate)
- Military Audit Project v. Casey, 656 F.2d 724 (D.C. Cir. 1981) (establishes framework for FOIA exemptions and government’s burden)
