Corrow v. Dept of Corrections et al

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
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THOMAS CORROW, 	ORDER
22-CV-02005 (NRM) (LGD)
Plaintiff,
-against-
CO ROMANO, CO SANTORELLI, CO CORPORAL
MAGREENE, sued in their professional and personal
capacities; MEDICAL DEPARTMENT,
Defendants.
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THOMAS CORROW,
25-CV-05953 (NRM) (LGD)
Plaintiff,
-against-
CAPTAIN DONNELLI # 1278; C/O GONZALEZ,
Defendants.
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THOMAS CORROW,
25-CV-05971 (NRM) (LGD)
Plaintiff,
-against-
P.O. JOHN D. WILLIAMS, Police Officer 67th PCT,
et al.,
Defendants.
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NINA R. MORRISON, United States District Judge:
In each of the three above-captioned actions, pro se Plaintiff Thomas Corrow, who is
currently incarcerated at Ulster Correctional Facility, has filed a motion for disclosure of
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information pursuant to the New York Freedom of Information Law, Public Officers Law § 84, et
seq., (“FOIL”), which permits individuals to request disclosure of some records collected by New
York state agencies. There is no basis for this Court to compel disclosure under FOIL, because
FOIL applies to state and municipal agencies, not the federal courts. Federal courts do not have
independent jurisdiction to enforce state laws granting public access to official state records.
Summa v. Richmond Cnty. Dist. Attorney’s Off., No. 25-CV-04283 (HG), 2025 WL 2597174, at
*3 (E.D.N.Y. Aug. 27, 2025) (noting that FOIL claims do not arise under federal law); Morrison
v. MTA New York City Transit, No. 24-CV-5992 (OEM), 2024 WL 4450778, at *2 (E.D.N.Y. Oct.
9, 2024). To the extent that Plaintiff seeks records maintained by state agencies, he must direct
his request to those agencies. Accordingly, Plaintiff’s request for information pursuant to FOIL is
denied.
The Clerk of Court is respectfully directed to docket this Order in each of the actions noted
above and to mail a copy of the Order to Plaintiff, noting the mailing on the docket.
SO ORDERED.
/s/ Nina R. Morrison
NINA R. MORRISON
United States District Judge
Dated: March 4, 2026
Brooklyn, New York
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