Matthew Hight v. DHS

Plain English (For Everyone)

If you ask the government for records, your request needs to be specific. The court ruled that Matthew Hight's request to the Department of Homeland Security was too broad. Because it was too vague, the agency wasn't required to search for the records, and the court denied his attempt to force them to respond.

For Legal Practitioners

The D.C. Circuit affirmed the denial of mandamus, holding that Hight's FOIA request was not 'reasonably describable' due to its overbreadth. This decision reinforces the principle that petitioners must meet a specificity threshold to compel agency action under FOIA, preventing unduly burdensome searches.

For Law Students

This case illustrates the 'reasonably describable' standard for FOIA requests. The D.C. Circuit affirmed that overly broad requests, like Hight's to DHS, do not obligate agencies to search, and mandamus relief is inappropriate when this standard is not met.

Newsroom Summary

A federal appeals court ruled that the Department of Homeland Security does not have to search for records if a request is too vague. The court found Matthew Hight's request was overly broad, upholding the agency's decision not to comply.

Standard of Review

De novo review. The D.C. Circuit reviews a district court's denial of a petition for a writ of mandamus de novo, meaning it examines the legal issues anew without deference to the lower court's decision.

Procedural Posture

The case reached the D.C. Circuit on appeal from the district court's denial of Matthew Hight's petition for a writ of mandamus. Hight sought to compel the Department of Homeland Security (DHS) to produce records under the Freedom of Information Act (FOIA).

Burden of Proof

The burden of proof is on the petitioner (Matthew Hight) to demonstrate that the agency (DHS) has a clear legal duty to comply with the FOIA request and that the request is reasonably specific. The standard is whether the request is 'reasonably describable'.

Legal Tests Applied

Statutory References

Key Legal Definitions

Rule Statements

"A request is not reasonably descriptive if it is so broad that it would require the agency to undertake an unduly burdensome search."

"The district court did not err in denying Hight’s petition for a writ of mandamus because his FOIA request was not reasonably descriptive."

Scenario: You want to get all emails sent by a specific government official over their entire career.

Your Rights: You have the right to request government records under FOIA, but your request must be specific enough for the agency to reasonably locate them. A request for 'all emails' from an official's entire career would likely be considered too broad.

What To Do: Narrow your request by specifying date ranges, keywords, or specific topics to make it 'reasonably describable' and increase the likelihood of agency compliance.

Scenario: You submitted a FOIA request to an agency, and they denied it, claiming it was too broad.

Your Rights: You have the right to challenge an agency's determination that your FOIA request is too broad. However, you must be able to show that your request *is* reasonably specific and does not impose an undue burden on the agency.

What To Do: If your request is denied for overbreadth, review it and consider resubmitting a more narrowly tailored request with specific dates, subjects, or individuals to meet the 'reasonably describable' standard.

Is it legal to ask the government for any record I want?

No, it depends. While the Freedom of Information Act (FOIA) grants you the right to request federal agency records, your request must be 'reasonably describable,' meaning it needs to be specific enough for the agency to locate the records without an undue burden.

Applies to federal agencies in the United States.

For FOIA requesters

Individuals and organizations seeking government records must ensure their requests are specific and narrowly tailored. Overly broad or vague requests are likely to be denied, and courts will uphold agency decisions not to comply if the request is not 'reasonably describable'.

For Federal agencies

Agencies are protected from having to conduct excessively broad or burdensome searches. The ruling affirms their ability to deny requests that do not meet the 'reasonably describable' standard, saving them significant resources.

Q: What is Matthew Hight v. DHS about?

Matthew Hight v. DHS is a case decided by D.C. Circuit on May 2, 2025.

Q: What court decided Matthew Hight v. DHS?

Matthew Hight v. DHS was decided by the D.C. Circuit, which is part of the federal judiciary. This is a federal appellate court.

Q: When was Matthew Hight v. DHS decided?

Matthew Hight v. DHS was decided on May 2, 2025.

Q: What is the citation for Matthew Hight v. DHS?

The citation for Matthew Hight v. DHS is . Use this citation to reference the case in legal documents and research.

Q: What was the main issue in Matthew Hight v. DHS?

The main issue was whether Matthew Hight's Freedom of Information Act (FOIA) request to the Department of Homeland Security (DHS) was specific enough to be considered 'reasonably describable.' The court had to decide if DHS was legally obligated to search for records based on Hight's request.

Q: What is a writ of mandamus?

A writ of mandamus is a court order that compels a government official or agency to perform a duty they are legally required to do. In this case, Hight asked for one to force DHS to produce records.

Q: Is Matthew Hight v. DHS published?

Matthew Hight v. DHS is a published, precedential opinion. Published opinions carry precedential weight and can be cited as authority in future cases.

Q: What was the ruling in Matthew Hight v. DHS?

The court ruled in favor of the defendant in Matthew Hight v. DHS. Key holdings: The court held that a writ of mandamus is an extraordinary remedy and is only appropriate when a plaintiff has a clear right to the relief sought and the defendant has a clear duty to perform the act requested.; The court affirmed that FOIA requests must be reasonably specific to enable an agency to locate responsive records, and overly broad requests that do not meet this standard are properly denied.; The court found that Hight's request, which sought 'all records' concerning his immigration proceedings without further narrowing criteria, was too broad and not reasonably describable.; The court concluded that DHS's determination that the request was not reasonably describable was not arbitrary, capricious, or contrary to law, and therefore, Hight did not have a clear right to the relief sought.; The court rejected Hight's argument that the agency should have assisted him in narrowing his request, stating that FOIA does not impose a duty on agencies to reformulate vague or overly broad requests..

Q: Why is Matthew Hight v. DHS important?

Matthew Hight v. DHS has an impact score of 15/100, indicating narrow legal impact. This decision reinforces the principle that FOIA requesters must exercise diligence in formulating specific requests. It clarifies that agencies are not obligated to assist requesters in refining overly broad demands, and that mandamus relief is inappropriate when a request fails to meet the 'reasonably describable' standard, thereby managing agency resources and preventing fishing expeditions.

Q: What precedent does Matthew Hight v. DHS set?

Matthew Hight v. DHS established the following key holdings: (1) The court held that a writ of mandamus is an extraordinary remedy and is only appropriate when a plaintiff has a clear right to the relief sought and the defendant has a clear duty to perform the act requested. (2) The court affirmed that FOIA requests must be reasonably specific to enable an agency to locate responsive records, and overly broad requests that do not meet this standard are properly denied. (3) The court found that Hight's request, which sought 'all records' concerning his immigration proceedings without further narrowing criteria, was too broad and not reasonably describable. (4) The court concluded that DHS's determination that the request was not reasonably describable was not arbitrary, capricious, or contrary to law, and therefore, Hight did not have a clear right to the relief sought. (5) The court rejected Hight's argument that the agency should have assisted him in narrowing his request, stating that FOIA does not impose a duty on agencies to reformulate vague or overly broad requests.

Q: What are the key holdings in Matthew Hight v. DHS?

1. The court held that a writ of mandamus is an extraordinary remedy and is only appropriate when a plaintiff has a clear right to the relief sought and the defendant has a clear duty to perform the act requested. 2. The court affirmed that FOIA requests must be reasonably specific to enable an agency to locate responsive records, and overly broad requests that do not meet this standard are properly denied. 3. The court found that Hight's request, which sought 'all records' concerning his immigration proceedings without further narrowing criteria, was too broad and not reasonably describable. 4. The court concluded that DHS's determination that the request was not reasonably describable was not arbitrary, capricious, or contrary to law, and therefore, Hight did not have a clear right to the relief sought. 5. The court rejected Hight's argument that the agency should have assisted him in narrowing his request, stating that FOIA does not impose a duty on agencies to reformulate vague or overly broad requests.

Q: What cases are related to Matthew Hight v. DHS?

Precedent cases cited or related to Matthew Hight v. DHS: Citizens for Responsibility and Ethics in Washington v. U.S. Dep't of Justice, 746 F.3d 1051 (D.C. Cir. 2014); Competitive Enterprise Inst. v. Office of Sci. & Tech. Policy, 827 F.3d 145 (D.C. Cir. 2016); I.R.S. v. McMillen, 137 S. Ct. 1759 (2017).

Q: What does 'reasonably describable' mean for a FOIA request?

A FOIA request is 'reasonably describable' if it is specific enough for a reasonable person to identify the records sought and for the agency to locate them without an unduly burdensome search. It prevents requests that are too vague or broad.

Q: Why was Matthew Hight's FOIA request denied?

Hight's FOIA request was denied because the D.C. Circuit found it to be overly broad and lacking sufficient specificity. It did not meet the 'reasonably describable' standard required by FOIA.

Q: What is the standard of review for this type of case?

The D.C. Circuit reviewed the district court's decision de novo. This means the appeals court examined the legal issues from scratch, without giving deference to the lower court's ruling.

Q: What statute governs this type of request?

The primary statute governing this case is the Freedom of Information Act (FOIA), specifically 5 U.S.C. § 552(a)(3), which outlines the requirements for public access to agency records.

Q: Can an agency be forced to search for records if the request is too broad?

No, an agency is not legally required to conduct an 'unduly burdensome' search. If a FOIA request is found to be overly broad and not reasonably describable, the agency can deny it, and a court will likely uphold that denial.

Q: How does Matthew Hight v. DHS affect me?

This decision reinforces the principle that FOIA requesters must exercise diligence in formulating specific requests. It clarifies that agencies are not obligated to assist requesters in refining overly broad demands, and that mandamus relief is inappropriate when a request fails to meet the 'reasonably describable' standard, thereby managing agency resources and preventing fishing expeditions. As a decision from a federal appellate court, its reach is national. This case is moderate in legal complexity to understand.

Q: What happens if my FOIA request is deemed too broad?

If your FOIA request is deemed too broad, the agency can deny it. You may have the option to resubmit a more specific request that meets the 'reasonably describable' standard to ensure the agency can locate the records.

Q: How can I make my FOIA request more specific?

To make a FOIA request more specific, include precise date ranges, relevant keywords, specific individuals or departments, and clearly define the subject matter. Avoid vague terms like 'all' or 'any'.

Q: What is the consequence of this ruling for future FOIA requesters?

Future FOIA requesters must be diligent in crafting specific requests. This ruling reinforces that overly broad requests will likely be denied, and courts will uphold agency decisions based on the 'reasonably describable' standard.

Q: Does this ruling mean agencies never have to produce broad categories of documents?

Not necessarily. While this ruling affirmed that overly broad requests are not enforceable, agencies may still produce broad categories of documents if the request is structured in a way that is still 'reasonably describable' and not unduly burdensome.

Q: When was the Freedom of Information Act enacted?

The Freedom of Information Act (FOIA) was enacted by Congress in 1966 and became effective in 1967. It has been amended several times since then.

Q: Has the 'reasonably describable' standard always been part of FOIA?

Yes, the requirement that a request must reasonably describe the records sought has been a fundamental part of FOIA since its inception in 1967, ensuring manageable agency responses.

Q: What was the docket number in Matthew Hight v. DHS?

The docket number for Matthew Hight v. DHS is 23-5273. This identifier is used to track the case through the court system.

Q: Can Matthew Hight v. DHS be appealed?

Potentially — decisions from federal appellate courts can be appealed to the Supreme Court of the United States via a petition for certiorari, though the Court accepts very few cases.

Q: What is the procedural posture of this case?

The case came to the D.C. Circuit as an appeal from a district court's denial of Matthew Hight's petition for a writ of mandamus. Hight sought to compel the Department of Homeland Security (DHS) to respond to his FOIA request.

Q: What is the burden of proof on someone filing a FOIA request?

The burden is on the requester to demonstrate that their request is 'reasonably describable' and that the agency has a clear legal duty to comply. The requester must show the request is specific enough to allow the agency to locate the records.