American Farm Bureau v. EPA, No. 15-1234 (8th Cir. 2016)Annotate this Case
Plaintiffs (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.