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Forest Guardians v. Federal Emergency Management Agency

Citation: 35 ELR 20120
No. No. 04-2056, (10th Cir., 06/15/2005)

The court dismissed an environmental group's action to compel the Federal Emergency Management Agency to produce electronic mapping files that identify the location of structures insured under its national flood insurance program. The group sought the information in conjunction with its study of endangered species in floodplain areas. The request, however, is exempt from disclosure under the Freedom of Information Act Exemption 6, which excludes "personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy." The privacy interest at stake in this case, even if de minimis, outweighs the public interest, which is nonexistent, since the group already possesses the hardcopy files.