Sandoval v. U.S. Dep't of Justice

Summary

Federal inmate's FOIA and Privacy Act claims dismissed on summary judgment for failure to exhaust administrative remedies as to FBI and BOP, and because the U.S. Attorney's Office conducted an adequate search and provided the 100 free pages to which plaintiff was entitled under FOIA and DOJ regulations. The court held that a FOIA requester must exhaust administrative remedies before suing, and that an agency's sworn affidavits demonstrating a reasonable search and compliance with fee limitations are sufficient to defeat claims of unlawful withholding. Plaintiff's unsupported allegations of innocence did not warrant Privacy Act record correction.

Holdings

1. Sandoval failed to exhaust administrative remedies because he did not appeal the agencies' initial responses.
2. The U.S. Attorney's Office conducted an adequate search; Sandoval's claim of unlawful withholding fails because he only requested 100 free pages and received that amount.
3. Sandoval's unsupported assertions of innocence do not warrant correction of records.

Questions Presented

1. Whether Sandoval exhausted his administrative remedies before filing FOIA and Privacy Act claims against the FBI and BOP.
2. Whether the U.S. Attorney's Office conducted an adequate search under FOIA and the Privacy Act, and whether Sandoval's Privacy Act correction claim fails.

Disposition

summary judgment granted