ALDF V. FDA

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ALDF filed a Freedom of Information Act (FOIA), 5 U.S.C. 552 et seq., action seeking to compel the FDA to release redacted data pertaining to information related to ALDF's FOIA request regarding egg-production farms in Texas. The district court ordered the release of information regarding the number of birds per cage at each farm. But the district court held on summary judgment that, under FOIA Exemption 4, the FDA properly withheld the other categories of information. The court agreed and concluded that the release of the redacted information would likely cause "substantial competitive harm" to the affected producers and farmers. In this case, the district court did not clearly err in finding that disclosure of the information was likely to cause commercial undercutting. Finally, the district court did not abuse its discretion by denying third-party discovery. Accordingly, the court affirmed the judgment. View "ALDF V. FDA" on Justia Law