District Court Decisions

Richardson v. DOJ, No. 09-1916, 2010 WL 3191796 (D.D.C. Aug. 13, 2010) (Huvelle, J.). The court rejects plaintiff's argument that he is entitled "to the release of all the information he requested because this information would have been available to him during the criminal proceedings either as Brady or Jencks Act . . . material." The court states that "[t]he FOIA confers no such entitlement" and that "[n]either a requester's reason for making his request nor his interest in the requested records is relevant in this context." Additionally, the court notes that "plaintiff's argument is misplaced 'because a Brady violation is a matter appropriately addressed to the court that sentenced [plaintiff], not through a FOIA action."