Case: American Oversight v. Federal Bureau of Investigation

1:26-cv-00020 | U.S. District Court for the District of District of Columbia

Filed Date: Jan. 5, 2026

Case Ongoing

Clearinghouse coding complete

Case Summary

This is a Freedom of Information Act case challenging the Federal Bureau of Investigation (FBI) and the Department of Justice (DOJ)'s withholding of records related to the January 6, 2021, attack on the U.S. Capitol and associated pardons. On January 5, 2025, American Oversight filed this lawsuit in the U.S. District Court for the District of Columbia. American Oversight is a nonpartisan, nonprofit organization focused on promoting government transparency and accountability by disseminating inf…

This is a Freedom of Information Act case challenging the Federal Bureau of Investigation (FBI) and the Department of Justice (DOJ)'s withholding of records related to the January 6, 2021, attack on the U.S. Capitol and associated pardons.

On January 5, 2025, American Oversight filed this lawsuit in the U.S. District Court for the District of Columbia. American Oversight is a nonpartisan, nonprofit organization focused on promoting government transparency and accountability by disseminating information to the public. The plaintiff sued the DOJ and FBI under the Freedom of Information Act (FOIA), which grants the public the legal right to request access to records from any federal government agency, after filing five requests with the departments and not receiving any records in response. The request sought text messages and emails from senior officials, including the Director of the FBI, Kash Patel, and former Deputy Director of the FBI Dan Bongino. American Oversight sought the requested information to shed light on the defendants’ communications regarding the events of January 6, 2021, including the attack on the U.S. Capitol to stop the certification of the 2020 presidential election, and President Trump’s pardons and commutations of individuals convicted of offenses related to those events. 

American Oversight sought a court order requiring the defendants to conduct a search reasonably calculated to uncover all records responsive to the request, with justifications for withholding any responsive records withheld under the claim of exemption, and enjoining the defendants from continuing to withhold any and all non-exempt records responsive to the FOIA request. This case was assigned to District Court Judge Ana C. Reyes. 

On March 20, 2026, the court ordered the parties to meet and confer to file a joint status report to address the status of the plaintiff’s FOIA request, the anticipated number of documents that will arise from the request, and the anticipated date(s) for release of the documents, among other things. 

On April 28, 2026, the FBI and DOJ released a joint status report stating that searches for records responsive to the plaintiff’s FOIA requests are ongoing and proposed filing another joint status report on or before June 29, 2026. 

This case is ongoing. 

Summary Authors

Madeline Dollard (6/17/2026)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/72106672/parties/american-oversight-v-federal-bureau-of-investigation/


Attorney for Plaintiff

Martinez, Daniel Havlir (District of Columbia)

Sparks, Benjamin A. (District of Columbia)

Attorney for Defendant

Zieman, Benjamin H. (District of Columbia)

Documents in the Clearinghouse

Documents in this case
1

1:26-cv-00020

Complaint

American Oversight v. Federal Bureau of Investigation et al.

Jan. 5, 2026

Jan. 5, 2026

Complaint
11

1:26-cv-00020

Joint Status Report

American Oversight v. Federal Bureau of Investigation et al.

April 28, 2026

April 28, 2026

Pleading / Motion / Brief

Docket

See docket on RECAP: https://www.courtlistener.com/docket/72106672/american-oversight-v-federal-bureau-of-investigation/

Last updated Sept. 28, 2026, 3:30 a.m.

Docket for: AMERICAN OVERSIGHT v. FEDERAL BUREAU OF INVESTIGATION
ECF Number Date Description Link
1 Jan. 5, 2026

COMPLAINT against All Defendants ( Filing fee $ 405 receipt number ADCDC-12166975) filed by AMERICAN OVERSIGHT. (Attachments: # 1 Civil Cover Sheet, # 2 Summons USAO, # 3 Summons AG, # 4 Summons FBI, # 5 Summons DOJ, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Exhibit D, # 10 Exhibit E)(Martinez, Daniel) (Attachment 1 replaced on 1/6/2026) (zjm). (Entered: 01/05/2026)

1 Civil Cover Sheet

View on RECAP

2 Summons USAO

View on PACER

3 Summons AG

View on PACER

4 Summons FBI

View on PACER

5 Summons DOJ

View on PACER

6 Exhibit A

View on PACER

7 Exhibit B

View on PACER

8 Exhibit C

View on PACER

9 Exhibit D

View on PACER

10 Exhibit E

View on PACER

Clearinghouse
2 Jan. 6, 2026

SUMMONS (4) Issued Electronically as to FEDERAL BUREAU OF INVESTIGATION, U.S. DEPARTMENT OF JUSTICE, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zjm) (Entered: 01/06/2026)

RECAP
3 Jan. 6, 2026

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by AMERICAN OVERSIGHT (Martinez, Daniel) (Entered: 01/06/2026)

RECAP
Jan. 6, 2026

Case Assigned/Reassigned

Jan. 6, 2026

Case Assigned to Judge Ana C. Reyes. (zjm)

4 Jan. 12, 2026

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. FEDERAL BUREAU OF INVESTIGATION served on 1/9/2026; U.S. DEPARTMENT OF JUSTICE served on 1/9/2026 (Attachments: # 1 Declaration)(Martinez, Daniel) (Entered: 01/12/2026)

RECAP
5 Jan. 12, 2026

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 1/9/2026., RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 1/6/2026. ( Answer due for ALL FEDERAL DEFENDANTS by 2/5/2026.) (See Docket Entry 4 to view document). (znmw) (Entered: 01/13/2026)

RECAP
Jan. 13, 2026

Summons Returned Executed as to U.S. Attorney General AND Summons Returned Executed in FOIA case as to U.S. Attorney

6 Jan. 30, 2026

Unopposed MOTION for Extension of Time to File Answer re 1 Complaint, by FEDERAL BUREAU OF INVESTIGATION, U.S. DEPARTMENT OF JUSTICE. (Zieman, Benjamin) (Entered: 01/30/2026)

RECAP
Feb. 2, 2026

MINUTE ORDER granting 6 Motion for Extension of Time to Answer. Defendants shall answer or otherwise respond to the Complaint on or before March 9, 2026. Signed by Judge Ana C. Reyes on 2/2/2026. (lcacr2)

Feb. 2, 2026

Order on Motion for Extension of Time to Answer

Feb. 2, 2026

Set/Reset Deadlines/Hearings

Feb. 2, 2026

Set/Reset Deadlines/Hearings: Answer or other response to complaint due by 3/9/2026. (zcdw)

7 March 9, 2026

ANSWER to Complaint by FEDERAL BUREAU OF INVESTIGATION, U.S. DEPARTMENT OF JUSTICE.(Zieman, Benjamin) (Entered: 03/09/2026)

RECAP
8 March 10, 2026

Standing Order

RECAP
March 10, 2026

.Order

March 10, 2026

Set/Reset Deadlines/Hearings

March 10, 2026

MINUTE ORDER. Cases filed under FOIA are exempt from the requirements of Federal Rule of Civil Procedure 26(f) and Local Civil Rule 16.3. See LCvR 16.3(b)(10). Accordingly, the Court hereby ORDERS the parties to meet and confer and file a joint status report on or before April 14, 2026. The joint status report should address, among other things, (1) the status of Plaintiff's FOIA requests; (2) the anticipated number of documents responsive to Plaintiff's FOIA requests; (3) the anticipated date(s) for release of those documents; and (4) whether a motion for a stay under Open America v. Watergate Special Prosecution Force, 547 F.2d 605 (D.C. Cir. 1976), is likely. As set forth in Section 5(d) of the Court's Standing Order, if the parties agree on a proposed schedule for submitting a further joint status report, they should assume that the Court approves the proposed date unless the Court enters an order to the contrary. Counsel shall not contact Chambers directly concerning scheduling or other matters, as Chambers personnel will not handle questions relating to the status or scheduling of pending matters, except in case of an emergency. Signed by Judge Ana C. Reyes on 3/10/2026. (lcacr2)

March 10, 2026

Set/Reset Deadlines/Hearings: Joint Status Report due by 4/14/2026. (zcdw)

9 April 9, 2026

Notice of Appearance

RECAP
10 April 14, 2026

Status Report

RECAP
11 April 28, 2026

Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION, U.S. DEPARTMENT OF JUSTICE. (Zieman, Benjamin) (Entered: 04/28/2026)

Clearinghouse
12 June 29, 2026

Status Report

RECAP
13 July 14, 2026

Notice of Appearance

RECAP
14 July 15, 2026

Notice of Withdrawal of Appearance

RECAP
15 Aug. 28, 2026

Status Report

RECAP

Case Details

State / Territory:

District of Columbia

Case Type(s):

Election/Voting Rights

Presidential/Gubernatorial Authority

Special Collection(s):

Trump Administration 1.0 & 2.0 FOIA cases

Trump Administration 2.0: Challenges to the Government

Key Dates

Filing Date: Jan. 5, 2026

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

American Oversight is a nonpartisan, nonprofit organization focused on promoting government transparency and accountability by disseminating information to the public.

Plaintiff Type(s):

Non-profit NON-religious organization

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Federal

Federal Bureau of Investigation

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

FOIA (Freedom of Information Act), 5 U.S.C. § 552

Other Dockets:

District of District of Columbia 1:26-cv-00020

Available Documents:

Complaint (any)

Trial Court Docket

Outcome

Prevailing Party: None Yet / None

Relief Sought:

Declaratory judgment

Document/Information

Injunction

Relief Granted:

None yet

Source of Relief:

None yet

Issues

Presidential/Gubernatorial Authority:

Access to information systems

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