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Center for Biological Diversity v. United States Department of State

ELR Citation: 48 ELR 20193
Nos. 18-563 (JEB), (D.D.C., 11/08/2018) (Boasberg, J.)

A district court dismissed a request by environmental groups to compel the State Department to release documents detailing U.S. greenhouse gas emissions as required by the U.N. Framework Convention on Climate Change. The groups sought to compel the submission of two required reports via the APA, and to obtain records pursuant to FOIA related to preparation of the reports. But the court determined that the groups failed to show how they were directly injured by not having access to the reports and thus lacked standing to bring their claims. The court therefore dismissed the groups' claims, giving them thirty days to file an amended complaint.