Datta v. United States
- Lewis Kaplan
- 1:14-cv-08653
- U.S. District Court · Southern District of New York
- 33
In Datta v. United States, Judge Kaplan denied Datta’s Freedom of Information Act request because it was filed in closed cases and sought court records.
Vikram Datta’s request for court-related records and clarification was denied; the United States was the respondent.
What happened
Datta v. United States involved Vikram Datta’s request for clarification and records concerning the government’s authority to prosecute him and the court’s rulings. He filed the request under the Freedom of Information Act in his completed criminal case and a concluded civil case involving an earlier challenge to his conviction.
Datta sought records about his arrest, indictments, sentencing, and the court’s jurisdiction. The opinion describes him as representing himself. The court noted that neither case remained pending.
Judge Lewis A. Kaplan denied the application. He explained that a Freedom of Information Act action must be filed as a new civil case in an appropriate venue, with the required filing fee unless fee relief is granted. He also explained that the requested records were from the court, and federal courts are excluded from the law’s definition of a government agency.
The detailed version
- Datta v. United States · No. 1:14-cv-08653
- Lewis Kaplan
- Feb. 2, 2024
Background
Vikram Datta, appearing without a lawyer, submitted an application under the Freedom of Information Act (FOIA), 5 U.S.C. § 552. The application was filed in connection with his completed criminal case and a concluded civil docket involving a prior challenge under 28 U.S.C. § 2255. Datta asked for clarification and records concerning the government’s authority to prosecute him and the court’s rulings. His requests included records concerning his arrest, indictments, sentencing, and the basis for the court’s jurisdiction.
Court’s Analysis
The court identified two reasons for denying the application. First, neither case in which Datta filed the application was still pending. The court stated that a person seeking relief under FOIA must start a new civil action in an appropriate venue and must pay the required filing fee unless the court grants relief from that fee.
Second, the court stated that the records Datta sought would come from the court. FOIA applies to a federal government “agency,” but the statutory definition of that term expressly excludes the courts of the United States. The court therefore did not treat Datta’s filing in the existing criminal or civil dockets as a proper FOIA action.
Disposition
Judge Lewis A. Kaplan denied the application. The order addressed the filing’s FOIA vehicle and the identity of the records’ custodian; it did not decide the merits of Datta’s challenges to his convictions, indictments, arrest, or sentence.
Read the full 33-page opinion on CourtListener, the free public archive maintained by the Free Law Project.