Natural Resource Defense Council v. Environmental Protection Agency

Docket Number20-422
Decision Date29 November 2021
The EPA appeals the district court's order requiring EPA to disclose twenty-eight records pursuant to a Freedom of Information Act (FOIA) request submitted by the NRDC. At issue is whether records reflecting an agency's discussions about how to communicate its policies to people outside the agency qualify for the deliberative process privilege and whether an agency must connect a record to a specific contemplated agency decision to claim the privilege The Second Circuit concluded that the...

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10 cases
  • Behar v. U.S. Dep't of Homeland Sec.
    • United States
    • U.S. Court of Appeals — Second Circuit
    • July 8, 2022
    ... ... First, the records are not "agency records" subject to the FOIA. Second, even if the ... 2016) (holding that the National Security Council is not an agency subject to the FOIA because it ... conclusion in part "because it is hard for us to ‘believe Congress intended that FOIA ... ...
  • Seife v. U.S. Food & Drug Admin.
    • United States
    • U.S. Court of Appeals — Second Circuit
    • August 5, 2022
    ... ... of pages of documents to the FDA, an agency within defendant-appellee Department of Health ... Customs and Border Prot. , 436 F. Supp. 3d 90, 113 (D.D.C. 2019) ... Small Bus. League v. Dep't of Def. , 411 F. Supp. 3d 824, 836 (N.D. Cal. 2019) ... at 18-19. Defendants, however, urge us to adopt the American Small Business League ... Nat. Res. Def. Council v. United States Env't Prot. Agency ... ...
  • Knight First Amendment Inst. at Columbia Univ. v. U.S. Citizenship & Immigration Servs.
    • United States
    • U.S. Court of Appeals — Second Circuit
    • April 6, 2022
    ... ... This case requires us to determine the scope of one such exemption ... Because DOS is a "mixed-function agency" performing both administrative and law ... C.L. Union v. U.S. Dep't of Def. , 901 F.3d 125, 133 (2d Cir. 2018), as amended ... Res". Def. Council v. U.S. E.P.A. , 19 F.4th 177, 184\xE2" ... ...
  • Sec. & Exch. Comm'n v. Ripple Labs Inc.
    • United States
    • U.S. District Court — Southern District of New York
    • April 11, 2022
    ... ... SEC, an essential link in the agency's deliberations ... about whether ... LLC v ... Consumer Fin. Prot. Bureau, 140 S.Ct. 2183, 2209 (2020) ... Nat'l ... Council of La Raza v. Dep't of Just., No. 03-cv-2559 ... Res ... Def. Council v. U.S. Env't Prot ... ...
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1 firm's commentaries
  • Ripple Effects Of Recent Discovery Decision In SEC v. Ripple Labs, Inc.?
    • United States
    • Mondaq United States
    • January 20, 2022
    ...they were prepared to help the agency formulate its position.'" Opinion,at 3 quoting Nat. Res. Def. Council v. U.S. Env't Prot. Agency, 19 F. 4th 177, 184 (2d Cir. 2021).1 The privilege will not apply to "purely factual" material not prepared to assist agency decision-makers in taking discr......