Smigelski v. FBI (S.D. Ohio) -- dismissing pro se plaintiff's FOIA claims without prejudice for filing suit just days after receiving a no-records response without pursuing an administrative appeal; overruling plaintiff's argument that exhaustion should be excused as futile due to defendants' allegedly inadequate search and retaliatory conduct; and dismissing with prejudice plaintiff's FOIA claims against Attorney General Pam Bondi and FBI Director Kash Patel as individuals, holding that FOIA applies only to agencies.
Summaries of published opinions issued in 2026 are available here. Earlier opinions are available for 2025, 2024, and from 2015 to 2023.