Central Platte Natural Res. Dist. v. U.S. Dept. of Agriculture, et al., No. 10-3205 (8th Cir. 2011)
Annotate this CaseAppellant sought disclosure of geospatial data from the USDA under the Freedom of Information Act (FOIA), 5 U.S.C. 552, and the Administrative Procedure Act (APA), 5 U.S.C. 701 et seq. At issue was whether the district court properly dismissed appellant's APA claim and granted summary judgment on its FOIA claim in favor of the USDA. The court held that the district court did not err in concluding that the USDA was not required to disclose the Geographic Information System (GIS) data where it properly determined that the 2008 Farm Bill was a withholding statute for purposes of FOIA exemptions. The court also held that the district court did not err in dismissing the APA claims where FOIA provided an adequate alternative remedy. Accordingly, the judgment of the district court was affirmed.
Court Description: Civil case - Administrative Law. District court did not err in deciding that the Freedom of Information Act did not require the FDA to disclose data from the agency's Geographic Information System as the 2008 Farm Bill qualified as a withholding statute under FOIA exemption 3; plaintiff's APA claim for the data was barred because FOIA created an adequate review mechanism for the decision to withhold the data.
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