# Bennett v. United States Postal Service

> District Court, District of Columbia · March 11, 2026

URL: https://www.frixlaw.com/law-library/cases/11274085

## Case

- **Court:** District Court, District of Columbia
- **Decided:** March 11, 2026
- **Precedential status:** Published
- **Opinion:** Opinion
- **Judges:** Judge Loren L. AliKhan
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/11274085

## How later opinions describe it (automated extraction)

- holding “that a pro se non-attorney may not recover attorney fees under” FOIA’s fee-shifting provision
- finding overbroad a request for all documents generated during the prior decade “concerning the activities” of two prison gangs

## Opinion text

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

DAVID BENNETT,

Plaintiff,

v. Civil Action No. 24 - 3668 (LLA)

UNITED STATES POSTAL SERVICE,

Defendant.

MEMORANDUM OPINION

Plaintiff David Bennett, proceeding pro se, filed this suit pursuant to the Freedom of

Information Act (“FOIA”), 5 U.S.C. § 552, seeking to compel the United States Postal Service

(“USPS”) to comply with his request for various records related to the USPS’s services. ECF

No. 1. The USPS has moved to dismiss the complaint. ECF No. 15. Mr. Bennett has also filed a

variety of motions: for judicial notice and the appointment of counsel and a guardian ad litem,

ECF Nos. 9, 13, for leave to intervene in a bankruptcy case as an interested party, ECF No. 25, for

leave to file a “Federal SLAPP Motion,” ECF No. 26, and for the court to provide involuntary

petition for bankruptcy forms, ECF No. 27. For the foregoing reasons, the court will grant the

USPS’s motion to dismiss, ECF No. 15, and deny Mr. Bennett’s pending motions.

I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY

The following factual allegations drawn from Mr. Bennett’s complaint, ECF No. 1, are

accepted as true for the purpose of evaluating the motion before the court, Am. Nat’l Ins. Co. v.

Fed. Deposit Ins. Corp., 642 F.3d 1137, 1139 (D.C. Cir. 2011). The court further takes judicial

notice of Mr. Bennett’s FOIA request, ECF No. 15-1, and the USPS’s response, ECF No. 15-2,
which are incorporated by reference into Mr. Bennett’s complaint, see Banneker Ventures, LLC v.

Graham, 798 F.3d 1119, 1133 (D.C. Cir. 2015); ECF No. 1, at 3-4.

Mr. Bennett is incarcerated at Yolo County Jail in Woodland, California. ECF No. 1, at 1;

ECF No. 1-3. He seeks records from the USPS about its “business” model because he wishes to

start a “sell-by-mail business.” ECF No. 1, at 1-3. By letter dated June 17, 2024, Mr. Bennett sent

the USPS a request seeking “Information and Records of Information about your service, how to

use your service as a consumer, How to do Business with your service, Partnerships, Contracts,

catalog[u]e, and your Brochure providing [a] listing of business opportunities available with your

service,” information about “how to use your service for online mailing service for Business

Partnering with you, and sell by mail [business] information for my magazine and Newspaper

article Business.” ECF No. 15-1, at 1-2; ECF No. 18, at 8. He also requested information about

a “Prison Stamp Exchange.” ECF No. 15-1, at 2; ECF No. 18, at 8. A representative from the

USPS denied the request, stating that FOIA “does not require the Postal Service to answer

questions, provide explanations or other information that is not contained in its records already in

existence, or render opinions.” ECF No. 15-2, at 1. 1 In response to the denial letter, Mr. Bennett

made a “Non[-]FOIA” request asking for “the [s]ame [r]ecord and information.” ECF No. 1, at 4.

He received no response to that subsequent request. Id.

On November 12, 2024, Mr. Bennett filed this action against USPS employees Kevin

Rayburn and Coletta Hughes. ECF No. 1. He filed a motion for leave to proceed in forma pauperis

in June 2025, ECF No. 2, which the court granted, ECF No. 4. The court, explaining that FOIA

cases may proceed only against a federal agency and not an individual, dismissed Mr. Rayburn

1
Mr. Bennett asserts in his opposition to the USPS’s motion to dismiss that this is not the real
denial letter he received. ECF No. 18, at 1-2.

2
and Ms. Hughes and substituted the USPS as the defendant. ECF No. 5. Mr. Bennett filed motions

for the court to take judicial notice and for the appointment of counsel, ECF No. 9, and for the

appointment of counsel and a guardian ad litem, ECF No. 13, both of which the USPS opposed,

ECF No. 16. The USPS filed its motion to dismiss, ECF No. 15, which is fully briefed, ECF

Nos. 15, 18, 19. Mr. Bennett thereafter filed a motion to intervene in a bankruptcy proceeding,

ECF No. 25, a motion to file a “Federal SLAPP Motion,” ECF No. 26, and a motion to assist him

in commencing an involuntary bankruptcy proceeding against a business, ECF No. 27.

II. LEGAL STANDARDS

A. FOIA

The purpose of FOIA is “to pierce the veil of administrative secrecy and to open agency

action to the light of public scrutiny.” Am. C.L. Union v. U.S. Dep’t of Just., 655 F.3d 1, 5

(D.C. Cir. 2011) (quoting Dep’t of Air Force v. Rose, 425 U.S. 352, 361 (1976)). FOIA requires

an agency to release non-exempt records if it receives a request that “(i) reasonably describes such

records and (ii) is made in accordance with published rules stating the time, place, fees (if any),

and procedures to be followed.” 5 U.S.C. § 552(a)(3)(A). FOIA places the initial burden of

drafting a reasonably descriptive request on the plaintiff. See Corley v. Dep’t of Just., 998 F.3d

981, 989 (D.C. Cir. 2021). Accordingly, an agency’s obligations under FOIA begin only “once an

agency has received a proper FOIA request.” Citizens for Resp. & Ethics in Wash. v. Fed. Election

Comm’n, 711 F.3d 180, 185 n.3 (D.C. Cir. 2013).

A plaintiff seeking judicial review under FOIA must generally exhaust its administrative

remedies before filing suit. Wilbur v. Cent. Intel. Agency, 355 F.3d 675, 677 (D.C. Cir. 2004) (per

curiam). “[F]ailure to comply with FOIA and agency requirements—by, for example, failing to

reasonably describe the records—‘amounts to a failure to exhaust administrative remedies, which

3
warrants dismissal.’” Frost Brown Todd LLC v. Ctrs. for Medicare & Medicaid Servs.,

No. 21-CV-2784, 2024 WL 450056, at *2 (D.D.C. Feb. 5, 2024) (quoting Dale v. Internal

Revenue Serv., 238 F. Supp. 2d 99, 102-03 (D.D.C. 2002)). FOIA’s exhaustion requirements are

jurisprudential, not jurisdictional, and “failure to exhaust precludes judicial review if the purposes

of exhaustion and the particular administrative scheme support such a bar.” Wilbur, 355 F.3d

at 677 (internal quotation marks omitted) (quoting Hidalgo v. Fed. Bureau of Investigation, 344

F.3d 1256, 1258-59 (D.C. Cir. 2003)).

While FOIA cases are typically decided on motions for summary judgment, see Leopold

v. Dep’t of Def., 752 F. Supp. 3d 66, 74 (D.D.C. 2024), a motion to dismiss under Federal Rule of

Civil Procedure 12 can be the appropriate vehicle for determining whether the plaintiff has filed a

procedurally compliant FOIA request and exhausted his administrative remedies, see Citizens for

Resp. & Ethics in Wash. v. U.S. Dep’t of Just., 922 F.3d 480, 487-88 (D.C. Cir. 2019); Hidalgo,

344 F.3d at 1260.

B. Federal Rule of Civil Procedure 12(b)(6)

Under Rule 12(b)(6), the court will dismiss a complaint that does not “contain sufficient

factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft

v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)).

“A claim has facial plausibility when the plaintiff pleads factual content that allows the court to

draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. In

evaluating a motion under Rule 12(b)(6), a court accepts all well-pleaded factual allegations in the

complaint as true. See Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam); see also Atherton

v. D.C. Off. of Mayor, 567 F.3d 672, 681 (D.C. Cir. 2009). Although the plausibility standard does

not require “detailed factual allegations,” it “requires more than labels and conclusions, and a

4
formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555.

Nor will “‘naked assertion[s]’ devoid of ‘further factual enhancement’” suffice. Iqbal, 556 U.S.

at 678 (alteration in original) (quoting Twombly, 550 U.S. at 557).

In determining whether a complaint fails to state a claim, a court may consider only the

facts alleged in the complaint and “any documents either attached to or incorporated in the

complaint and matters of which [the court] may take judicial notice.” N. Am. Butterfly Ass’n v.

Wolf, 977 F.3d 1244, 1249 (D.C. Cir. 2020) (alteration in original) (quoting Hurd v. District of

Columbia, 864 F.3d 671, 678 (D.C. Cir. 2017)).

C. Pro Se Litigants

Pleadings by pro se litigants are generally held “to less stringent standards than formal

pleadings drafted by lawyers.” Haines v. Kerner, 404 U.S. 519, 520 (1972) (per curiam). This

liberal construction “is not, however, a license to ignore the Federal Rules of Civil Procedure.”

Sturdza v. United Arab Emirates, 658 F. Supp. 2d 135, 137 (D.D.C. 2009). Thus, “the complaint

must still ‘present a claim on which the [c]ourt can grant relief’” in order to defeat a motion to

dismiss under Rule 12(b)(6). Smith v. Scalia, 44 F. Supp. 3d 28, 36 (D.D.C. 2014) (quoting Budik

v. Dartmouth-Hitchcock Med. Ctr., 937 F. Supp. 2d 5, 11 (D.D.C. 2013)).

III. DISCUSSION

A. Motion to Dismiss

A FOIA request must “reasonably describe[]” the records being requested. 5 U.S.C.

§ 552(a)(3)(A). A request meets this requirement if it is “sufficient [to] enable[] a professional

employee of the agency who was familiar with the subject area of the request to locate the record

with a reasonable amount of effort.” Truitt v. Dep’t of State, 897 F.2d 540, 545 n.36 (D.C. Cir.

5
1990) (quoting H.R. Rep. No. 93-876 (1974)). “Broad, sweeping requests lacking specificity are

not sufficient.” Dale, 238 F. Supp. 2d at 104. But even where a request has “sufficient precision

to enable the agency to identify [the records],” “[a]n agency need not honor a request that requires

‘an unreasonably burdensome search.’” Am. Fed’n of Gov’t Emps., Loc. 2782 v. U.S. Dep’t of

Com., 907 F.2d 203, 209 (D.C. Cir. 1990) (quoting Goland v. Cent. Intel. Agency, 607 F.2d 339,

353 (D.C. Cir. 1978)). That is especially so where the requester seeks “a vast quantity of material”

that is not tailored to the requester’s purpose for requesting the material. Id. Because it is “the

requester’s responsibility to frame [its] request[] with sufficient particularity to ensure that

searches are not unreasonably burdensome[] and to enable the searching agency to determine

precisely what records are being requested,” an agency is not required to respond to a request that

falls short in either respect. SAI v. Transp. Sec. Admin., 315 F. Supp. 3d 218, 248 (D.D.C. 2018)

(second alteration in original) (quoting Assassination Archives & Rsch. Ctr., Inc. v. Cent. Intel.

Agency, 720 F. Supp. 217, 219 (D.D.C. 1989)).

The USPS contends that Mr. Bennett’s FOIA request did not reasonably describe the

records sought and that the request would require an overly burdensome search and post-search

review efforts. 2 ECF No. 15, at 6-9. Because the court agrees that Mr. Bennett has not reasonably

2
The USPS also argues that the court should dismiss Mr. Bennett’s California state law claims
pursuant to Federal Rule of Civil Procedure 12(b)(1). ECF No. 15, at 5-6. In his opposition,
Mr. Bennett disclaims making any state law claims and instead clarifies that he merely cited state
law to inform the court’s interpretation of FOIA. ECF No. 18, at 2-3. The USPS is correct that
the California Public Records Act, which by its own terms applies only to state actors, see Cal.
Gov’t Code § 7922.530, cannot waive the federal government’s sovereign immunity from suit, see
Sookra v. Pfizer, Inc., No. 24-CV-1249, 2025 WL 341732, at *4 (D.D.C. Jan. 30, 2025), report
and recommendation adopted, No. 24-CV-1249, 2025 WL 1545354 (D.D.C. Mar. 26, 2025)
(dismissing claims brought against federal government defendants for violation of a state law).

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described the records he requests, the court will dismiss the complaint without reaching the USPS’s

arguments about burden.

1. Vagueness

The USPS first argues that Mr. Bennett’s requests for effectively “every piece of

information about any service ever offered by the United States Postal Service” and every piece

of information about doing business with the USPS are unclear as to which particular documents

Mr. Bennett actually seeks. ECF No. 15, at 7-8. The court agrees that Mr. Bennett’s request does

not identify what records are being sought with sufficient precision.

“The linchpin inquiry is whether the agency is able to determine precisely what records are

being requested—[b]road, sweeping requests lacking specificity are not sufficient.” Gun Owners

of Am., Inc. v. Fed. Bureau of Investigation, 594 F. Supp. 3d 37, 43 (D.D.C. 2022) (alteration in

original) (internal quotation marks omitted) (quoting Dale, 238 F. Supp. 2d at 104). Mr. Bennett’s

requests are exactly the type of sweeping request that courts in this Circuit routinely deem

impermissibly vague. For example, Mr. Bennett asks the USPS for “Records of Information about

your service.” ECF No. 15-1, at 1; ECF No. 18, at 8. This request for information “about” a

general topic does not reasonably describe the records sought because it “seek[s] all materials

related to a certain topic.” Frost Brown Todd LLC, 2024 WL 450056, at *3. Courts routinely

dismiss similarly worded requests that “seek records ‘pertaining to,’ ‘relating to,’ or ‘concerning’

broad subject areas.” Bader Fam. Found. v. U.S. Equal Empl. Opportunity Comm’n,

No. 23-CV-976, 2025 WL 915563, at *4 (D.D.C. Mar. 26, 2025); see About, Merriam-Webster

Dictionary (defining “about” to mean “with regard to” or “concerning”). While requests

containing such phrases are not categorically overbroad, courts usually disapprove of such

requests, see Gun Owners, 594 F. Supp. 3d at 47-48 & n.5 (collecting cases), the subjectivity of

7
which could “sweep in any communication,” Am. Ctr. for L. & Just. v. U.S. Dep’t of Homeland

Sec., 573 F. Supp. 3d 78, 85 (D.D.C. 2021); see, e.g., Louise Trauma Ctr., LLC v. U.S. Immigr. &

Customs Enf’t, No. 20-CV-3787, 2025 WL 637369, at *7 (D.D.C. Feb. 27, 2025) (rejecting a

request for “all records concerning [an agency’s] ‘information processing system’ and the

‘electronic searches’ it permits”); Pinson v. U.S. Dep’t of Just., 245 F. Supp. 3d 225, 244-45

(D.D.C. 2017) (finding overbroad a request for all documents generated during the prior decade

“concerning the activities” of two prison gangs). The use of “about” in Mr. Bennett’s request fails

to “clearly identify what relation . . . records must have to the topic[s] it has identified.” Cato Inst.

v. Dep’t of Def., No. 21-CV-1223, 2023 WL 3231445, at *3 (D.D.C. May 3, 2023). Indeed, taken

literally, Mr. Bennett’s request could apply to just about any document in the USPS’s possession

related to its mail service. Because “a record may [be ‘about’] something without specifically

mentioning it,” the breadth of Mr. Bennett’s request “leaves the agency to guess at [Mr. Bennett’s]

intent.’” Sack v. Cent. Intel. Agency, 53 F. Supp. 3d 154, 164 (D.D.C. 2014). FOIA does not

require agencies to engage in such guesswork.

Another part of Mr. Bennett’s request exemplifies the same issue: he seeks “(5) Contracts.”

ECF No. 15-1, at 1; ECF No. 18, at 8. But what contracts, or other records about contracting, does

Mr. Bennett seek? Over what time period? Pertaining to which issues? It cannot be, for example,

that Mr. Bennett seeks every employment contract that the USPS has entered in with its hundreds

of thousands of employees. Again, a reasonable agency would have little choice but to guess at

Mr. Bennett’s intent.

Indeed, Mr. Bennett’s requests are even less specific than those deemed impermissibly

vague by other courts in this Circuit. Take, for example, Anand v. U.S. Department of Health and

Human Services, No. 21-CV-1635, 2023 WL 2646815 (D.D.C. Mar. 27, 2023). The plaintiff there

8
requested that the Department of Health and Human Services provide “all reports from Blue Cross

Blue Shield corporation to [the Office of the Inspector General] concerning improper prescribing

of opiates by specific physicians.” Id. at *2. The plaintiff’s request pertained to a specific policy

involving one corporation, yet the court still concluded that such a request would require a fishing

expedition because the “concerning” language was too vague. Id. at *13. The court explained that

such requests require the agency to devise some method for discerning what information

“concerns” a topic, in part because a record may “concern” a topic without literally mentioning

that topic. Id. The court also found that the word “improper” was insufficiently limiting because

“there is latitude in what constitutes ‘improper describing of opiates’ such that it would not allow

[the agency] to identify the records sought.” Id. Mr. Bennett’s requests are facially much broader

than the request at issue in Anand: he requests information about not just one policy or person, but

the entire set of services the USPS provides, including the provision of mail and selling of stamps.

Mr. Bennett responds that his request was reasonably described by search terms including

“‘Identifiable,’ ‘Searchable,’ ‘Reproducible,’ ‘Responsive,’ ‘Retrievable,’ ‘downloadable,’ and in

an ‘online or Electronic Format’ located on Defendant[’]s website.” ECF No. 18, at 2. The USPS

points out that none of these words appear in the text of Mr. Bennett’s FOIA request, but even if

they had, those words do not clarify what records would or would not be responsive. ECF No. 19,

at 2. Mr. Bennett’s proposed limiting language, even if it were included in the original FOIA

request, misses the point. Words like “responsive,” searchable,” and “downloadable” do nothing

to limit the substantive scope of Mr. Bennett’s request. “Responsive” repeats an adjective already

contained in FOIA’s definition of a search, see 5 U.S.C. § 552(a)(3)(D), and the latter two terms

merely specify the format of record Mr. Bennett wishes to receive. In short, Mr. Bennett’s broad

descriptions “leave the unfortunate FOIA processor assigned to [his] case in a hopeless muddle

9
without clear guidance about what documents are being sought.” Am. Ctr. for L. & Just., 573 F.

Supp. 3d at 85.

Finally, Mr. Bennett suggests that “Defendant[] had reason to know that certain locations

may have responsive Documents in a[n] Electronic Form or Format.” ECF No. 18, at 6-7. But

even if the USPS were able to locate some records it believed were responsive to Mr. Bennett’s

request, its duty to disclose records is triggered only by a request that reasonably describes the

records sought such that an agency would know which records are responsive and which are not.

See Evans v. Fed. Bureau of Prisons, 951 F.3d 578, 583 (D.C. Cir. 2020). As the court has already

explained, Mr. Bennett’s request does not meet this requirement, so the USPS was not required to

produce any records. 3

2. Mr. Bennett’s Additional Arguments

Mr. Bennett makes several additional arguments in his opposition to the motion to dismiss.

None cuts against the court’s conclusion that he failed to reasonably describe the records sought.

First, he alleges that “what [the USPS] claim[s] to be [the] denial letter is not.” ECF No. 18, at 1-2.

But besides his conclusory statement that the USPS has provided the court with a fraudulent denial

letter, Mr. Bennett fails to explain why the denial letter is relevant to the question whether the

USPS was required to respond to his FOIA request.

3
As noted, the USPS also argues that Mr. Bennett’s request is invalid because it would require an
unreasonably burdensome search and post-search review. ECF No. 15, at 8-9. While the court
would ordinarily address all of the USPS’s arguments for dismissal, the question of a search’s
burden is generally better suited for resolution at summary judgment. See Protect the Pub.’s Tr.
v. U.S. Dep’t of Lab., No. 22-CV-2849, 2023 WL 6160014, at *2 n.2 (D.D.C. Sep. 21, 2023). In
any event, because the USPS’s argument about the burden of the search largely repeats its
vagueness argument, which the court has already addressed, the court need not reach the question
of burden.

10
Second, Mr. Bennett requests attorney’s fees and costs. ECF No. 18, at 5. At the outset,

the court notes that Mr. Bennett could not recover attorney’s fees because he is proceeding pro se.

Benavides v. Bureau of Prisons, 993 F.2d 257, 260 (D.C. Cir. 1993) (holding “that a pro se

non-attorney may not recover attorney fees under” FOIA’s fee-shifting provision). Further,

Mr. Bennett is not eligible for costs or fees under 5 U.S.C. § 552(a)(4)(E)(i) because he has not

“substantially prevailed” on his request for records—indeed, the agency has not produced any of

his requested records. And while Mr. Bennett claims that he is entitled to fees under 42 U.S.C.

§ 1988, that provision applies only to actions enforcing certain civil rights statutes, not FOIA suits.

Third, Mr. Bennett claims that the USPS’s response to his FOIA request violated his First,

Eleventh, and Fourteenth Amendment rights. ECF No. 18, at 4. “Because the FOIA’s

‘comprehensive scheme’ provides the exclusive remedy of an injunction for claims arising from

the withholding of agency records, [Mr. Bennett] may not recover monetary damages and he states

no claim upon which relief may be granted for the separately alleged constitutional violations.”

Pickering-George v. Registration Unit, DEA/DOJ, 553 F. Supp. 2d 3, 4 (D.D.C. 2008) (quoting

Johnson v. Exec. Off. for U.S. Att’ys, 310 F.3d 771, 777 (D.C. Cir. 2002)). 4

* * *

For the foregoing reasons, the court will grant the USPS’s motion to dismiss Mr. Bennett’s

FOIA complaint, ECF No. 15. And because Mr. Bennett cannot cure the deficiencies in his case

4
In any event, Mr. Bennett’s claim under the Fourteenth Amendment is actually one under the
Fifth Amendment because the Fourteenth Amendment applies only to actions by a state, not by
federal agencies like the USPS. S.F. Arts & Athletics, Inc. v. U.S. Olympic Comm., 483 U.S. 522,
542 n.21 (1987) (assessing the plaintiff’s discrimination claim against a federal entity under the
Fifth Amendment).

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by amending his complaint, the court will dismiss the complaint with prejudice. See Firestone v.

Firestone, 76 F.3d 1205, 1209 (D.C. Cir. 1996).

B. Mr. Bennett’s Motions to Appoint Counsel

Mr. Bennett has also twice requested that this court appoint him counsel to aid him in the

presentation of his case. ECF Nos. 9, 13. 5 The court has the power to appoint counsel to pro se

litigants who have been granted leave to proceed in forma pauperis pursuant to 28 U.S.C. § 1915.

Loc. Civ. R. 83.11(b)(3). The court’s determination should take into account the “[n]ature and

complexity of the action,” the “[p]otential merit” of the plaintiff’s claims, the plaintiff’s

“[d]emonstrated inability . . . to retain counsel by other means,” and whether and to what extent

the interests of justice will be served by the appointment of counsel. Id. Mr. Bennett has stated

his claims clearly, such that the court has been able to discern that he fails to state FOIA a claim

upon which relief can be granted. “Because the legal issues in this case are not complex, and

because [Mr. Bennett’s] claims lack merit, the interests of justice would not be served by diverting

the limited resources of the pro bono panel to this case.” Brown v. Fed. Aviation Admin.,

No. 23-CV-2251, 2025 WL 958321, at *12 (D.D.C. Mar. 31, 2025); see Timms v. U.S. Att’y Gen.,

No. 24-CV-3100, 2024 WL 5294259, at *2 (D.D.C. Dec. 31, 2024) (denying request for

5
Mr. Bennett also asks the court to take judicial notice of his criminal proceedings and other civil
actions in the U.S. District Court for the Eastern District of California and in the U.S. Court of
Appeals for the Ninth Circuit. See ECF No. 9; ECF No. 13, at 3 (noting that “[a]ll my Federal
complaints have been Dismissed for the same reason”). To the extent he requests review of
“wrongfully denied” motions in other cases, ECF No. 13, at 4, it is well-settled that “[a] federal
district court lacks jurisdiction to review decisions of other federal courts,” Smalls v. United States,
471 F.3d 186, 192 (D.C. Cir. 2006).

12
appointment of counsel as moot after dismissing the case). The court will accordingly deny

Mr. Bennett’s motions for appointment of counsel, ECF Nos. 9, 13. 6

C. Mr. Bennett’s Remaining Motions

Mr. Bennett has three additional motions pending before the court. He first filed a “Motion

for Leave to File for Bankruptcy Requesting for Forms and Self-Help Information.” ECF No. 25,

at 1. In that motion, Mr. Bennett claims he is an “interested party” in a bankruptcy proceeding in

Texas because the entity that filed for bankruptcy “might owe [him] money.” Id. at 1-2. He

requests a “status update” on that bankruptcy case, a list of related cases, and a packet of

information providing him with bankruptcy forms and other assistance. Id. at 3. The Clerk’s

Office has already mailed a bankruptcy packet and form to Mr. Bennett. See Nov. 6, 2025 Docket

Entry. If Mr. Bennett seeks to intervene in another lawsuit, he must file his request to intervene in

that lawsuit, not in this one. See Fed. R. Civ. P. 24(c).

Next, Mr. Bennett filed a “Motion for Leave to File Federal SLAPP Motion.” ECF No. 26,

at 1. This motion appears to reference California’s anti-SLAPP law, Cal. Civ. Proc. Code

§ 425.16. That statute provides protection to certain individuals who have been sued for engaging

in protected activity; it does not provide an affirmative cause of action entitling a plaintiff to relief

such as the records Mr. Bennett apparently seeks here. See Cal. Civ. Proc. Code § 425.16(b)(1).

To the extent Mr. Bennett seeks relief under a federal “SLAPP Act,” no such act exists.

6
The court will also deny Mr. Bennett’s request that the court appoint a “Guardian Ad Litem for
PC § 1370 competency proceedings.” ECF No. 13, at 6. The court understands Mr. Bennett to be
referencing the California Penal Code, which dictates the procedures for California state courts to
assess the mental competency of criminal defendants. See Cal. Pen. Code § 1370. But this action
is governed by federal law, not California law. And because the court is dismissing Mr. Bennett’s
case, his request for a guardian ad litem is moot.

13
Finally, Mr. Bennett filed a “Motion for Involuntary Petition For Individuals Filing for

Bankruptcy Forms,” in which he asked for “[a]ny [s]elf-[h]elp [i]nformation this court can

provide” for his filing of a “Traffic[k]ing Bankruptcy Personal Injury Complaint” in another

district. ECF No. 27, at 1-2. But Mr. Bennett provides no legal basis nor sufficient details for this

court to provide such information.

IV. CONCLUSION

For the foregoing reasons, the court will grant the USPS’s motion to dismiss, ECF No. 15,

and dismiss Mr. Bennett’s complaint, ECF No. 1, and the case with prejudice. The court will also

deny Mr. Bennett’s pending motions, ECF Nos. 9, 13, 25 to 27. A contemporaneous order will

issue.

LOREN L. ALIKHAN
United States District Judge
Date: March 11, 2026

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11274085. Public record. Not legal advice.