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American Farm Bureau Federation v. U.S. Environmental Protection Agency

ELR Citation: 45 ELR 20023
Nos. 13-1751, (D. Minn., 01/27/2015) (Montgomery, J.)

A district court held that livestock farm groups lack standing to bar EPA from releasing their members' personal information—including the physical address and other operational details about the farms—in response to environmental groups' FOIA requests for information about concentrated animal feeding operations. The farm groups argued that their members’ personal information is protected by FOIA Exemption 6, which safeguards “personal, medical, or similar" files from being released to prevent an "unwarranted invasion of personal privacy." But none of the individuals on whose behalf the farm groups seek relief have suffered or will imminently suffer direct injury as a result of EPA's anticipated actions. The information the groups want protected is easily accessible and widely available, often voluntarily so from the farmers who seek to promote their businesses. Under these circumstances, EPA's distribution of already public information does not establish an injury for purposes of constitutional standing.