Case Explained: UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT RYAN BAUGH v. CENTRAL INTELLIGENCE AGENCY ) ) ) ) ) ) ) ) )

Court: United States Court of Appeals for the Sixth Circuit

Filed: 2026-07-10

The sixth-circuit affirmed the district court’s dismissal of Ryan Baugh’s lawsuit against the Central Intelligence Agency for failure to state a claim under the Administrative Procedure Act (APA) and the Mandamus Act. The court held that Baugh lacked an adequate remedy in court because he could have pursued injunctive relief directly under the Freedom of Information Act (FOIA) and the Privacy Act, which provide identical remedies for the production of unredacted records. The court reasoned that Executive Order 12,968 and implementing agency guidance do not create independent procedural or substantive rights enforceable against the United States; rather, they merely restate existing obligations under FOIA and the Privacy Act. Consequently, Baugh’s attempt to bypass these statutes by filing under the APA was barred because a cause of action exists only when no other adequate remedy is available. Additionally, the court rejected Baugh’s request for jurisdictional discovery, ruling that the district court did not abuse its discretion in denying it, as the complaint itself established sufficient facts for subject matter jurisdiction and such discovery would amount to an impermissible “fishing expedition.” The practical consequence is that Baugh’s federal lawsuit was terminated without a merits determination of his redaction claims, leaving him with no judicial avenue to compel the release of the unredacted file under the statutes he invoked.

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