Barth v. United States Department of Justice

District Court, District of Columbia·Decided March 3, 2026·No. Civil Action No. 2023-2920·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JOHN S. BARTH,

Plaintiff,

v. Civil Action No. 23-2920 (CKK)

U.S. DEPARTMENT OF JUSTICE,

Defendant.

MEMORANDUM OPINION

(March 3, 2026)

In this action, Plaintiff John S. Barth, proceeding pro se, challenges three federal agencies’

responses to a Freedom of Information Act (“FOIA”) request that he filed seeking records about himself. Compl., Dkt. No. 1. Now pending before this Court is a [45] Motion for Summary Judgment by DOJ, the only remaining Defendant in this case, and a [49] Motion for Recusal and for other relief filed by Plaintiff Barth. Upon consideration of the parties’ submissions,1 the relevant legal authority, and the entire record, the Court shall DENY Plaintiff Barth’s motion for recusal and for other relief and shall GRANT Defendant DOJ’s motion for summary judgment.

I. BACKGROUND

This case arises from a FOIA request that Plaintiff Barth submitted in February 2021 seeking records about himself. Compl., Dkt. No. 1; Pl.’s Exs., Dkt. No. 1-1, at 3; see also Decl. of Jonathan M. Breyan (“Breyen Decl.”), Dkt. No. 45-3, ¶ 4.

1 The Court’s consideration has focused on the following documents, including the attachments and exhibits thereto:

• Defendant U.S. Department of Justice’s Motion for Summary Judgment (“Def.’s Mot.”), Dkt. No. 45;

• Plaintiff Barth’s Memorandum in Opposition to the Defendant’s Motion (“Pl.’s Opp’n”), Dkt. No. 46; and • Plaintiff Barth’s Motion for Recusal and for “Order of Compliance with the Freedom of Information Act”

(“Pl.’s Mot.”), Dkt. No. 49.

In an exercise of its discretion, the Court concludes that oral argument is not necessary to the resolution of the issues pending before the Court. See LCvR 7(f).

As Plaintiff Barth explains in his Complaint, he sought these records because he suspected that various federal agencies may have received false information about him. See Compl. ¶¶ 1– 3. Plaintiff Barth explains that he believes that this false information may have affected the agencies’ willingness to investigate information that he has submitted for their consideration about an alleged racketeering scheme involving various “Florida politicians of one party.”2 See id. ¶ 1.

Plaintiff Barth submitted his FOIA request to the Office of the Attorney General (“OAG”), which is a component of the U.S. Department of Justice (“DOJ”). See Pl.’s Exs., Dkt. No. 1-1, at 2; Breyen Decl. ¶ 5. DOJ’s Office of Information Policy (“OIP”), which processes FOIA requests submitted to OAG, responded to Plaintiff Barth by letter approximately one week after he submitted this request. Breyen Decl. ¶¶ 1, 6. In its letter, OIP advised Plaintiff Barth that it had located 26 pages of material that was responsive to his FOIA request. Id. ¶ 6. However, the letter advised that “[b]ecause this material originated with or is of primary interest to the Criminal Division,” OIP would refer the material to the Criminal Division for processing and a direct response. Id.; see also Pl.’s Exs., Dkt No. 1-1, at 6 (copy of letter). Two days later, the Criminal Division sent Plaintiff Barth a letter acknowledging that it had received the referral from OIP and would disclose all non-exempt information to him “as soon as practicable.” See Pl.’s Exs., Dkt. No. 1-1, at 7 (copy of letter).

Before the Criminal Division finished processing the records at issue, Plaintiff Barth filed an administrative appeal of OIP’s response. See Breyen Decl. ¶ 7. The appeals staff responded by letter, advising that DOJ regulations allow an appeal “only after there has been an adverse decision by a component.” Id. ¶ 8; see also Pl.’s Exs., Dkt No. 1-1, at 8 (copy of letter). Because

2 Plaintiff Barth has filed at least five federal lawsuits based on his underlying racketeering allegations, including one in this District in which he sought to compel various federal agencies to investigate. See Barth v. United States, No. 22-cv-0955, Dkt. No. 40 at 1–2 (D.D.C. Dec. 15, 2022) (JEB) (collecting cases). Other district judges—not the undersigned—have dismissed all five of these lawsuits. See id. at 1–2, 7.

Plaintiff Barth had not yet received an adverse determination, the appeals staff concluded that there was no action to be considered on appeal. See Breyen Decl. ¶ 8. Instead, it forwarded a copy of his appeal to the Criminal Division and advised that he should contact that Division for further information. Id.

In September 2023, after receiving no response from the Criminal Division for more than two years, Plaintiff Barth filed this action against the U.S. Department of Justice (“DOJ”), the Federal Bureau of Investigation (“FBI”), and Homeland Security Investigations (“HSI”), alleging that they had failed to meet their disclosure obligations in response to his February 2021 FOIA request. See Compl., Dkt. No. 1. This Court later dismissed Defendants FBI and HSI from this action on Defendants’ motion because the record established that these agencies had not received Plaintiff Barth’s FOIA request. See Mem. Op. & Order, Dkt. No. 23.

This Court also denied a motion for summary judgment by Plaintiff Barth, in which he argued that DOJ, FBI, and HSI had committed perjury and obstruction of justice and failed to comply with their obligations to respond to his FOIA requests. See Mem. Op. & Order, Dkt. No. 23. Plaintiff Barth also sought an order requiring the Defendants to investigate his allegations of wrongdoing by Florida officials, which this Court denied as outside the scope of his Complaint and beyond the Court’s power to grant in this case. See Minute Order (Feb. 25, 2025). Plaintiff Barth later renewed these arguments in several submissions seeking reconsideration, which this Court denied. See Mem. Op. & Order, Dkt. No. 35; Order, Dkt. No. 38; Minute Order (Apr. 18, 2025).

In October 2024, Defendant DOJ produced three documents to Plaintiff Barth in response to his FOIA request, totaling 26 pages. See Status Report (Nov. 27, 2024), Dkt. No. 37.

Defendant DOJ has now filed a motion for summary judgment, arguing that it has complied with its FOIA obligations by conducting a reasonable search for responsive records and releasing all non-exempt responsive records to Plaintiff Barth. Def.’s Mot., Dkt. No. 45. Plaintiff Barth opposes DOJ’s motion, renewing arguments that he has presented in his previous submissions. See Pl.’s Opp’n, Dkt. No. 46. He also moved to recuse this Court and for an order directing the Defendants to comply with their FOIA obligations. Pl.’s Mot., Dkt. No. 49.

The parties’ motions are now ripe for decision.

II. LEGAL STANDARDS

A. Recusal A federal judge has a duty to recuse herself “in any proceeding in which [her] impartiality might reasonably be questioned.” 28 U.S.C. § 455(a). In this Circuit, a judge must be recused under this rule if “a reasonable and informed observer would question the judge’s impartiality.” District of Columbia v. Doe, 611 F.3d 888, 899 (D.C. Cir. 2010) (quoting SEC v. Loving Spirit Found. Inc., 392 F.3d 486, 494 (D.C. Cir. 2004)). When applying this standard, courts “take the perspective of a fully informed third-party observer who ‘understand[s] all the relevant facts’ and has ‘examined the record and the law.’” United States v. Cordova, 806 F.3d 1085, 1092 (D.C. Cir. 2015) (alteration in original) (quoting United States v. Holland, 519 F.3d 909, 914 (9th Cir. 2008)).

Recusal of a judge is an “extraordinary” measure that should not be “lightly granted.”

United States v. Pollard, 959 F.2d 1011, 1023 (D.C. Cir. 1992). Accordingly, “recusal must be limited to truly extraordinary cases where . . . the judge’s views have become ‘so extreme as to display clear inability to render fair judgment.’” Cobell v. Kempthorne, 455 F.3d 317, 332 (D.C. Cir. 2006) (quoting Liteky v. United States, 510 U.S. 540, 555 (1994)).

Free access — add to your briefcase to read the full text and ask questions with AI

Barth v. United States Department of Justice, (D.D.C. 2026).

Barth v. United States Department of Justice (Barth v. United States Department of Justice) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Liteky v. United States
510 U.S. 540 (Supreme Court, 1994)
District of Columbia v. Doe
611 F.3d 888 (D.C. Circuit, 2010)
Cobell, Elouise P. v. Kempthorne, Dirk
455 F.3d 317 (D.C. Circuit, 2006)
Morley v. Central Intelligence Agency
508 F.3d 1108 (D.C. Circuit, 2007)
Larson v. Department of State
565 F.3d 857 (D.C. Circuit, 2009)
United States v. Jonathan Jay Pollard
959 F.2d 1011 (D.C. Circuit, 1992)
United States v. Holland
519 F.3d 909 (Ninth Circuit, 2008)
Singh v. George Washington University
383 F. Supp. 2d 99 (District of Columbia, 2005)
Chennareddy v. Walker
282 F.R.D. 9 (District of Columbia, 2012)
Elouise Cobell v. Sally Jewell
802 F.3d 12 (D.C. Circuit, 2015)
United States v. William Cordova
806 F.3d 1085 (D.C. Circuit, 2015)
Miller v. Casey
730 F.2d 773 (D.C. Circuit, 1984)