Argus Leader Media v. Food Marketing Institute, No. 17-1346 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed on remand the district court's conclusion that Exemption 4 of the Freedom of Information Act (FOIA) did not apply to SNAP redemption information. The court rejected the USDA's claim that release of the relevant information would cause competitive injury among the covered grocery retailers and held that the claim was speculative. In this case, evidence showed that the contested data—which was nothing more than annual aggregations of SNAP redemptions—lacked the specificity needed to gain material insight into an individual store's financial health, profit margins, inventory, marketing strategies, sales trends, or market share. Furthermore, there was no meaningful evidence that retailers would end their SNAP participation if the contested data were released.
Court Description: Kelly, Author, with Gruender and Beam, Circuit Judges] Civil case - FOIA. For the court's prior opinion in the matter, see Argus Leader Media v. U.S. Dep't of Agric., 740 F.3d 1172 (8th Cir. 2014), which held that Exemption 3 did not apply to the contested data concerning SNAP redemption information; on remand, the issue was whether Exemption 4 covering trade secrets and commercial or financial information obtained from a person and privileged and confidential applied to prevent release of the data; the court's finding that Exemption 4 did not apply because the USDA's claim that release of the information would cause competitive injury among the covered grocery retailers was speculative is affirmed; the record established the retailers already had access to large quantities of data about their competitors and existing models which explained consumer behavior.
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.