American Farm Bureau v. EPA, No. 15-1234 (8th Cir. 2016)
Annotate this CasePlaintiffs (the Associations) challenged the district court's ruling that they lack Article III standing to bring a "reverse" Freedom of Information Act (FOIA), 5 U.S.C. 552, 706(2)(A), claim against the EPA. Plaintiffs challenge the EPA's disclosure of certain information about concentrated animal feeding operations, contending that this disclosure is an unlawful release of their members’ personal information. The court concluded that, assuming that plaintiffs' claim would be successful on the merits, the associations have established a concrete and particularized injury in fact traceable to the EPA’s action and redressable by judicial relief. Therefore, the court concluded that the district court erred in dismissing this case for lack of standing. The court also concluded that the EPA abused its discretion in deciding that the information at issue was not exempt from mandatory disclosure under Exemption 6 of FOIA. Accordingly, the court reversed and remanded for the district court to consider the associations’ request for injunctive relief.
Court Description: 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.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.