Telematch, Inc. v. AGRI, No. 20-5378 (D.C. Cir. 2022)Annotate this Case
Telematch, Inc. is a commercial vendor of agricultural data. In 2018 and 2019, it submitted to USDA seven FOIA requests for records containing farm numbers, tract numbers, and customer numbers. USDA withheld the numbers under Exemptions 3 and 6. But it released or offered to release a statistical version of the files in accordance with section 8791(b)(4)(B). It also released payment information for the 2018 Conservation Reserve Program pursuant to section 8791(b)(4)(A). Telematch sued to challenge the USDA’s withholding of the farm, tract, and customer numbers. Both parties moved for summary judgment and attached statements of material facts to their motions.
The district court granted the government’s motion for summary judgment. The court held that USDA properly withheld the farm and tract numbers under Exemption 3, because the numbers are “geospatial information” covered by section 8791(b)(2)(B). Telematch appealed.
The DC Circuit affirmed. The court explained that farm and tract numbers identify a specific area of farmland in a specific location. They serve as a shorthand reference to individual plots of land. In this respect, they are analogous to a street address or latitude and longitude coordinates. They are, therefore “geospatial information” properly withheld under section 8791(b)(2)(B). Further, the court explained it need not definitively resolve whether farm and tract numbers meet these two statutory definitions. Neither of them applies to section 8791. Thus, the court held that the USDA permissibly withheld the requested farm, tract, and customer numbers.