University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Rahim v. Federal Bureau of Investigation NS-LA-0001
Docket / Court 2:11-cv-02850-SM-ALC ( E.D. La. )
State/Territory Louisiana
Case Type(s) National Security
Attorney Organization Center for Constitutional Rights
Case Summary
On November 16, 2011, an individual resident of Louisiana filed a lawsuit in the United States District Court for the Eastern District of Louisiana against the U.S. Department of Justice ("DOJ") and the Federal Bureau of Investigation ("FBI"). The plaintiff, represented by various public interest ... read more >
On November 16, 2011, an individual resident of Louisiana filed a lawsuit in the United States District Court for the Eastern District of Louisiana against the U.S. Department of Justice ("DOJ") and the Federal Bureau of Investigation ("FBI"). The plaintiff, represented by various public interest and private counsel, asked the court for declaratory and injunctive relief, claiming that defendants violated the Freedom of Information Act ("FOIA") by failing to make records available.

Following Hurricane Katrina, the plaintiff co-founded Common Ground Relief ("CGR") to provide short-term relief to Gulf Coast storm victims, as well as long-term support for rebuilding communities in the greater New Orleans, Louisiana area. After discovering that one of CGR's employees was an FBI informant, the plaintiff submitted a FOIA request to the FBI seeking documents pertaining to the informant and either the plaintiff or CGR. The FBI denied the FOIA request, stating that it would not respond to a FOIA request concerning an individual absent a "privacy waiver" from that individual. The plaintiff appealed the denial, but the DOJ affirmed the FBI's refusal to produce the documents.

On May 31, 2013, the District Court (Judge Susie Morgan) granted the defendants' motion for summary judgment. The Court found as a matter of law that the plaintiff failed to exhaust his administrative remedies regarding his request for records pertaining to himself and CGR. In addition, with respect to the plaintiff's request for records pertaining to the FBI informant, the Court found that the plaintiff failed to produce evidence that any alleged government impropriety occurred. Finally, the Court concluded that if any exclusion was in fact employed by the defendants as to the records requested, it was justified. On May 31, 2013, the Court dismissed the plaintiff's claims with prejudice.

Michael Mirdamadi - 10/06/2013


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Issues and Causes of Action
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Issues
Defendant-type
Jurisdiction-wide
General
Records Disclosure
Terrorism/Post 9-11 issues
Plaintiff Type
Private Plaintiff
Causes of Action Freedom of Information Act (FOIA), 5 U.S.C. § 552
Defendant(s) Federal Bureau of Investigation
United States Department of Justice
Plaintiff Description An individual resident of Louisiana who organized a relief organization named Common Ground Relief following Hurricane Katrina.
Indexed Lawyer Organizations Center for Constitutional Rights
Class action status sought No
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer Yes
Nature of Relief None
Source of Relief None
Form of Settlement None on record
Order Duration not on record
Case Closing Year 2013
Case Ongoing No
Additional Resources
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Links Guest Post: New Resource — Civil Rights Litigation Clearinghouse FISA Archives
Just Security
Posted: Jun. 26, 2014
By: Margo Schlanger
[ Detail ] [ External Link ]

Docket(s)
2:11−cv−02850 (E.D. La.) 05/31/2013
NS-LA-0001-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Complaint for Injunctive and Declaratory Relief 11/16/2011
NS-LA-0001-0001 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order and Reasons 05/31/2013 (947 F.Supp.2d 631) (E.D. La.)
NS-LA-0001-0002 PDF | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Judgment 05/31/2013 (E.D. La.)
NS-LA-0001-0003 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Morgan, Donna Sue (E.D. La.)
NS-LA-0001-0002 | NS-LA-0001-0003 | NS-LA-0001-9000
Monitors/Masters None on record
Plaintiff's Lawyers Finger, Davida (Louisiana)
NS-LA-0001-0001 | NS-LA-0001-9000
Godchaux, Sara H. (Louisiana)
NS-LA-0001-9000
Goodman, William Harry (Michigan)
NS-LA-0001-0001
Hurwitz, Julie H. (Michigan)
NS-LA-0001-0001
Patel, Sunita (New York)
NS-LA-0001-0001 | NS-LA-0001-9000
Quigley, William Patrick (Louisiana)
NS-LA-0001-0001 | NS-LA-0001-9000
Swanson, Miles W. (Louisiana)
NS-LA-0001-0001 | NS-LA-0001-9000
Defendant's Lawyers Dupre, Brock Darren (Louisiana)
NS-LA-0001-9000
Humphreys, Bradley Philip (District of Columbia)
NS-LA-0001-9000
Shapiro, Elizabeth J. (District of Columbia)
NS-LA-0001-9000
Other Lawyers None on record

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