ALDF V. FDA, No. 13-17131 (9th Cir. 2016)
Annotate this CaseALDF filed a Freedom of Information Act (FOIA), 5 U.S.C. 552 et seq., action seeking to compel the FDA to release redacted data pertaining to information related to ALDF's FOIA request regarding egg-production farms in Texas. The district court ordered the release of information regarding the number of birds per cage at each farm. But the district court held on summary judgment that, under FOIA Exemption 4, the FDA properly withheld the other categories of information. The court agreed and concluded that the release of the redacted information would likely cause "substantial competitive harm" to the affected producers and farmers. In this case, the district court did not clearly err in finding that disclosure of the information was likely to cause commercial undercutting. Finally, the district court did not abuse its discretion by denying third-party discovery. Accordingly, the court affirmed the judgment.
Court Description: Freedom of Information Act. The panel affirmed the district court’s summary judgment in favor of the Food and Drug Administration (“FDA”), and its holding that under Freedom of Information Act (“FOIA”) Exemption 4, the FDA properly withheld categories of information requested by the Animal Legal Defense Fund regarding egg-production farms in Texas. FOIA Exemption 4 applies to “trade secrets and commercial or financial information obtained from a person and privileged or confidential.” 5 U.S.C. § 552(b)(4). The district court concluded that the FDA had established that the release of five categories of redacted information – total hen population, number of hen houses, number of floors per house, number of cage rows per house, and number of cage tiers per house – was likely to result in substantial competitive harm due to underbidding among egg producers; and the information was protected under Exemption 4. The panel held that the district court had an adequate factual basis to reach its decision. The panel also held that the district court did not clearly err in finding that disclosure of the redacted information was likely to cause substantial competitive harm to the affected egg producers and farmers. Finally, the panel held that the district court did not abuse its discretion by denying third-party discovery. ALDF V. FDA 3 In a concurring per curiam opinion, the panel wrote separately to explain why it thought that the court should reconsider en banc the standard of review that is applied to appellate review of summary judgments in FOIA cases.
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