DISCLAIMER: The following unofficial case summaries are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
151234P.pdf 09/09/2016 American Farm Bureau v. EPA
U.S. Court of Appeals Case No: 15-1234
U.S. District Court for the District of Minnesota - Minneapolis
[PUBLISHED] [Colloton, Author, with Loken and Murphy, Circuit Judges]
Civil case - Freedom of Information Act. In this "reverse" Freedom of
Information Act action alleging the EPA's disclosure of certain
information about concentrated animal feeding operations was an unlawful
release of the plaintiff associations' members' personal information, the
district court erred in dismissing the action on the ground plaintiffs
lacked Article III standing; assuming, for purposes of standing analysis,
that plaintiffs' claim would be successful on the merits, the plaintiffs
have established a concrete and particularized injury in fact traceable to
the EPA's action and redressable by judicial relief; the court further
determines that the EPA abused its discretion in deciding that the
information at issue was not exempt from mandatory disclosure under
Exemption 6 of FOIA; the dismissal of the action is reversed, and the
matter is remanded for the district court to consider the plaintiffs'
request for injunctive relief.