Watson v. U.S. Department of Justice

CourtDistrict Court, District of Columbia
DecidedSeptember 10, 2020
DocketCivil Action No. 2018-1645
StatusPublished

This text of Watson v. U.S. Department of Justice (Watson v. U.S. Department of Justice) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Watson v. U.S. Department of Justice, (D.D.C. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

BOBBY KEITH WATSON,

Plaintiff,

v. No. 18-cv-1645 (DLF)

U.S. DEPARTMENT OF JUSTICE, et al.,

Defendants.

MEMORANDUM OPINION

Bobby Keith Watson, acting pro se, brings this lawsuit against the Department of Justice,

the U.S. Attorney’s Office for the Eastern District of Tennessee, and the Federal Bureau of

Investigation (FBI) under the Freedom of Information Act, 5 U.S.C. § 552 et seq. (FOIA).

Compl., Dkt. 1. Before the Court is Watson’s Motion to Show Cause, Dkt. 30, which, along

with Watson’s premature Motion for Summary Judgment, Dkt. 13, the Court construes as a

motion for summary judgment. Also before the Court is the defendants’ Motion to Dismiss, Or

in the Alternative, Motion for Summary Judgment, Dkt. 36, which the Court considers as a

motion for summary judgment. For the reasons that follow, the Court will deny Watson’s

motion and grant the defendants’ motion.

I. BACKGROUND

In December 2011, Watson submitted a FOIA request to the FBI. See Defs.’ Statement

of Undisputed Material Facts ¶ 5, Dkt. 36. The FBI informed Watson that his request did not

contain enough information for an accurate search. Id. ¶ 6. It also provided follow-up steps for

Watson to complete his request. Id. In response, Watson provided the FBI with the information

it needed to complete the search. Id. ¶ 7. The FBI then began searching its Central Records System (CRS) in accordance with Watson’s request. Id. In June of 2012, the FBI informed

Watson that it had reviewed over 250 pages and would release 111 of them. Id. ¶ 8. The rest

would be withheld under various statutory exemptions. Id.

In September 2015, Watson submitted a FOIA request to the U.S. Attorney’s Office for

the Eastern District of Tennessee. See id. ¶ 1. He sought documents related to his prosecution in

that district. Id. The U.S. Attorney’s Office then forwarded the request to the Executive Office

for United States Attorneys (EOUSA), as required by Department of Justice policy. Id. The

EOUSA then asked the U.S. Attorney’s Office to conduct a search responsive to Watson’s

request. Id. ¶ 2. The U.S. Attorney’s Office conducted the search, and the EOUSA provided a

final response to Watson in December of 2016. Id. The EOUSA’s response informed Watson of

his right to administratively appeal the decision, yet he did not do so. Id. ¶ 4; see also Pl.’s Mot.

for Summ. J. at 20–21 (Attach. 1).

Also in December 2016, the EOUSA referred 27 pages of FBI documents from the

EOUSA back to the FBI for it to make its own disclosure determination. Defs.’ Stmt. of

Undisputed Material Facts ¶ 10. The FBI then told Watson that all of the referred documents had

already been released to him in the course of Watson’s several previous requests over the years.

Id. ¶ 11.

In March 2017, Watson administratively appealed the FBI’s decision to the Office of

Information Policy. Id. ¶ 12. The Office of Information Policy affirmed the FBI’s decision that

all responsive documents had already been released to Watson. Id. ¶ 13. It further advised

Watson that he could request duplicate copies of these already-released documents from the FBI,

should he need them. Id.

2 About a year later, Watson brought this lawsuit. Id. ¶ 14. The FBI then re-reviewed the

documents referred from the EOUSA and released ten new pages of non-exempt information.

Id. ¶ 15. It also re-reviewed the 251 pages of FBI records and released four new pages of non-

exempt material (in addition to re-releasing the 111 pages it previously provided to Watson). Id.

¶ 16.

In this suit, Watson moved for summary judgment before the defendants had finished

their production of documents. Pl.’s Mot. for Summ. J. The Court denied that motion as

premature and advised Watson that he could file a motion for summary judgment at a later time.

See Minute Order of Apr. 25, 2019. After that, the defendants informed the Court that they had

been unable to reach Watson. See Defs.’ August 29, 2019 Status Report, Dkt. 22; Defs.’ Mot.

for Leave to File Status Report, Dkt. 23. The Court set a deadline for Watson to show cause why

the case should not be dismissed for failure to prosecute. Minute Order of Oct. 15, 2019. After

Watson missed that deadline, the Court dismissed this case. Order, Dkt. 24. Watson later filed a

change of address and made a motion to alter the judgment, which the Court granted. See Pl.’s

Mot. to Alter J., Dkt. 28. Watson again missed the filing deadline, and the Court ordered him to

show cause why the case should not be dismissed for a second time. See Minute Order of Jan.

31, 2020. He filed a motion to show cause which the Court construed as a motion for summary

judgment incorporating his earlier, untimely motion for summary judgment. See Minute Order

of Feb. 27, 2020. The defendants then cross-moved for summary judgment. See Defs.’ Mot. for

Summ. J. The Court warned Watson, pursuant to Fox v. Strickland, 837 F.2d 507 (D.C. Cir.

1988), of the consequences of failing to respond to the defendants’ arguments and factual

assertions under the Federal Rules of Civil Procedure and the Local Rules. See Minute Order of

July 20, 2020. The two motions for summary judgment are now ripe for the Court’s review.

3 II. LEGAL STANDARD

Rule 56 of the Federal Rules of Civil Procedure mandates that “[t]he court shall grant

summary judgment if the movant shows that there is no genuine dispute as to any material fact

and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). “Materiality

is, of course, a function of the applicable legal standard, which in this case is that an agency

responding to a FOIA request must conduct a search reasonably calculated to uncover all

relevant documents, and, if challenged, must demonstrate beyond material doubt that the search

was reasonable.” Kowalczyk v. DOJ, 73 F.3d 386, 388 (D.C. Cir. 1996) (internal quotation

marks omitted). All facts and inferences must be viewed in the light most favorable to the

requester and the agency bears the burden of showing that it complied with FOIA. Chambers v.

U.S. Dep’t of Interior, 568 F.3d 998, 1003 (D.C. Cir. 2009).

“The system of disclosure established by the FOIA is simple in theory. A federal agency

must disclose agency records unless they may be withheld pursuant to one of the nine

enumerated exemptions listed in [5 U.S.C.] § 552(b).” DOJ v. Julian, 486 U.S. 1, 8 (1988).

“[F]ederal courts . . . rely on government affidavits to determine whether the statutory

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Related

United States Department of Justice v. Julian
486 U.S. 1 (Supreme Court, 1988)
Yates v. District of Columbia
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344 F.3d 1256 (D.C. Circuit, 2003)
Wilbur v. Central Intelligence Agency
355 F.3d 675 (D.C. Circuit, 2004)
Sussman v. United States Marshals Service
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Morley v. Central Intelligence Agency
508 F.3d 1108 (D.C. Circuit, 2007)
Thomas C. Fox v. Marion D. Strickland
837 F.2d 507 (D.C. Circuit, 1988)
Chester Kowalczyk v. Department of Justice
73 F.3d 386 (D.C. Circuit, 1996)

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