Atchafalaya Basinkeeper, Inc. v. U.S. Army Corps of Engineers

CourtDistrict Court, E.D. Louisiana
DecidedJanuary 25, 2022
Docket2:21-cv-00317
StatusUnknown

This text of Atchafalaya Basinkeeper, Inc. v. U.S. Army Corps of Engineers (Atchafalaya Basinkeeper, Inc. v. U.S. Army Corps of Engineers) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Atchafalaya Basinkeeper, Inc. v. U.S. Army Corps of Engineers, (E.D. La. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

ATCHAFALAYA BASINKEEPER, CIVIL ACTION INC., ET AL.

VERSUS NO: 21-317

UNITED STATES ARMY CORPS OF SECTION: "A" (5) ENGINEERS

ORDER AND REASONS The following motions are before the Court: Motion for Summary Judgment (Rec. Doc. 15), filed by Defendant United States Army Corps of Engineers (“USACE”), and Motion to Defer/Deny Defendant’s Motion for Summary Judgment (Rec. Doc. 28), filed by Plaintiffs Atchafalaya Basinkeeper, Inc. (“Atchafalaya”), Louisiana Crawfish Producers Association-West, and Healthy Gulf. Both motions are opposed. The motions, submitted for consideration on November 10, 2021, and October 27, 2021, respectively, are before the Court on the briefs without oral argument.1 For the reasons that follow, the Motion for Summary Judgment is GRANTED IN PART AND DENIED IN PART and the Motion to Defer/Deny is DENIED. I. BACKGROUND This Freedom of Information Act (“FOIA”) case involves a dispute between Plaintiffs and the Defendant federal agency, USACE. Plaintiffs filed this lawsuit under the

1 Oral argument has been requested but the Court is not persuaded that oral argument would be helpful.

Page 1 of 24 FOIA, 5 U.S.C. § 552, to remedy the alleged failure of USACE to timely respond to and produce any or all responsive records for eight FOIA requests concerning projects in the Atchafalaya Basin. (Rec. Doc. 16 at ¶ 3, First Amended Complaint). On December 12, 2018, January 21, 2020, September 23, 2020, November 4, 2020, November 24, 2020, and December 10, 2020, Plaintiffs submitted a total of eight FOIA requests to USACE. (Id.). According to Plaintiffs, these requests were related to assessing damage to the Atchafalaya Basin caused by sedimentation from USACE’s water diversion projects, or plans and permits for similar projects in the basin. (Id.). Plaintiffs filed this lawsuit against USACE on February 12, 2021, alleging inter alia that

since receiving the requests, USACE has withheld information from Plaintiffs through its complete failure to respond to some record requests, its delayed responses to others, and its ongoing improper withholding of records responsive to seven of their eight requests. (Id. at ¶ 4). Specifically, Plaintiffs claim that USACE has violated, and continues to violate, 5 U.S.C. § 552(a)(3) of the FOIA by failing to perform an adequate search for records responsive to the requests and failing to promptly disclose records responsive to the requests by either withholding all responsive records or producing incomplete responsive records. (Id. at ¶¶ 112, 115–16, 118, 121–22, 125–27, 130–32, 135–37, 140–42, 145– 47). As to the East Grand Lake Request and the Bayou Bridge Request2, Plaintiffs also

allege that USACE violated § 552(a)(6)(4) of the FOIA by failing to notify Plaintiffs that it

2 The East Grand Lake Request and the Bayou Bridge Request were both submitted on December 12, 2018. See infra Part III.A.i. for a full description of both requests.

Page 2 of 24 would withhold responsive records and by failing to communicate the scope of the documents produced or withheld. (Id. at ¶¶ 113–14, 119–20). For the other six requests, Plaintiffs allege that USACE violated, and continues to violate, § 552(a)(6)(A) of the FOIA by failing to respond to the requests within 20 working days with a determination of whether it would comply or, if not, the reasons therefor. (Id. at ¶¶ 124, 129, 134, 139, 144). Finally, Plaintiffs allege that USACE has violated, and continues to violate, § 552(a)(7) of the FOIA because USACE did not provide estimated dates for completing its action on each request and did not provide Plaintiffs with tracking numbers timely or at all for the December 2018 and January 2020 requests. (Id. at ¶¶ 148–51).

Plaintiffs seek a declaration from this Court that USACE’s withholding of responsive records, failure to provide a response describing the scope of the records produced or withheld, failure to respond to the requests with a determination within 20 working days, and failure to perform an adequate search violates the FOIA. (Id. at p. 26, ¶¶ 1–4). Plaintiffs also request a declaration that USACE has a pattern, practice, or policy of violating the FOIA through its failure to respond to Plaintiffs’ FOIA and status requests timely or at all, and its failure to provide estimated dates or tracking numbers for said requests. (Id. at p. 27, ¶ 7–8). Second, Plaintiffs request the Court to order USACE to comply with the FOIA and immediately produce all records unlawfully withheld. (Id. at pp. 26–27, ¶¶ 5–6, 9). Plaintiffs also seek an order enjoining USACE from improperly

withholding any records and continuing its pattern, practice, or policy of violating the FOIA. (Id.). Third, Plaintiffs request a written finding that the circumstances surrounding USACE’s unlawful withholding of records responsive to its requests raises questions of

Page 3 of 24 whether USACE acted arbitrarily or capriciously. (Id. at p. 27–28, ¶ 11). Finally, Plaintiffs request attorney’s fees and other litigation costs to be assessed against USACE. (Id. at p. 27, ¶ 10). On June 22, 2021, Defendant USACE filed a motion for summary judgment (Rec. Doc. 15). USACE argues that contrary to Plaintiffs’ allegations, USACE searched for and found responsive documents, if they existed, to each of the eight subject FOIA requests and USACE produced all responsive documents without a single withholding, whether in whole or in part. (Rec. Doc. 15-1 at p. 10). A declaration by Stephen C. Roth, District Counsel and FOIA Officer for USACE in the New Orleans District, is attached in support

of USACE’s motion. (Rec. Doc. 15-2, Roth Declaration). According to USACE, the Roth Declaration establishes that its searches were made in good faith and were reasonably calculated to locate documents responsive to Plaintiffs’ FOIA requests. (Rec. Doc. 15-1 at p. 15). USACE claims the declaration also proves that USACE did not withhold any documents from Plaintiffs. (Id.). For these reasons, USACE argues that it is entitled to summary judgment. (Id.) Plaintiffs oppose the motion, arguing that (1) the motion fails to address the legal or factual questions raised by Plaintiffs, including their pattern and practice claims, (2) USACE “confirms the agency’s habitual and unabashed practice of ignoring the FOIA’s timing requirements . . . on all eight of Plaintiffs’ requests,” and (3) USACE fails to meet

its burdens on Plaintiffs’ more traditional claims. (Rec. Doc. 51 at pp. 1–2). Regarding the third assertion, Plaintiffs elaborate that USACE has not adequately responded to the East

Page 4 of 24 Grand Lake Request and Beau Bayou Request3, has not produced specific records, and did not adequately search for responsive records. (Id. at p. 4). On July 20, 2021, Plaintiffs filed a Motion to Defer or Deny Defendant’s Motion for Summary Judgment for prematurity or, alternatively, to extend the response time to allow Plaintiffs adequate time for discovery to oppose the motion. (Rec. Doc. 28). Plaintiffs claim that USACE’s Motion for Summary Judgment is premature because USACE did not address Plaintiffs’ pattern, policy, or practice claims and because Plaintiffs need more discovery. (Rec Doc. 28-1 at p. 3). USACE opposes the motion, asserting that discovery is premature at this stage of the litigation in an FOIA case and that its Roth Declaration is

accorded a presumption of good faith. (Rec. Doc. 44 at pp. 1–2). USACE attached a supplemental declaration by Stephen Roth4 addressing Plaintiffs’ concerns regarding USACE’s delays in responding to the requests and the circumstances surrounding later- found responsive documents. (Id.

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