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Center for Biological Diversity v. United States Department of State

ELR Citation: 49 ELR 20106
Nos. 18-563 (JEB), (D.D.C., 06/12/2019) (Boasberg, J.)

A district court dismissed a request to compel the State Department to release two reports concerning U.S. greenhouse gas emissions as required by the U.N. Framework Convention on Climate Change. An environmental group argued that the treaty required the agency to publicly disclose the reports, but the court found no treaty provision requiring it to do so. The group next argued the treaty body was required to make the reports publicly available when they were submitted. The court agreed, but found the treaty body was not a entity regulated by the U.S. government and thus that its disclosure obligation did not give rise to informational injury. It therefore dismissed the group's request for lack of standing.