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Center for Biological Diversity v. Bureau of Land Management

ELR Citation: 51 ELR 20039
Nos. 17-1208 (BAH), (D.D.C., 03/09/2021) (Howell, J.)

A district court denied motions for summary judgment in a lawsuit seeking FOIA disclosure of records regarding an order issued by the Secretary of the Interior concerning the federal coal program. An environmental group argued that DOI failed to conduct an adequate search for responsive records, failed to promptly disclose records responsive to the group's request, and failed to provide reasonably segregable portions of any responsive records exempt from disclosure. The court found that genuine issues existed as to the adequacy of DOI's search for responsive records that precluded summary judgment for either party. It therefore remanded to DOI to either supplement its declarations or undertake additional searches for responsive records.