Kentucky Heartwood, Inc. v. Moore

CourtDistrict Court, E.D. Kentucky
DecidedMarch 28, 2025
Docket6:22-cv-00169
StatusUnknown

This text of Kentucky Heartwood, Inc. v. Moore (Kentucky Heartwood, Inc. v. Moore) is published on Counsel Stack Legal Research, covering District Court, E.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kentucky Heartwood, Inc. v. Moore, (E.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY SOUTHERN DIVISION LONDON

KENTUCKY HEARTWOOD, INC., ) ) Plaintiff, ) ) No. 6:22-cv-169-REW-HAI v. ) ) U.S. FOREST SERVICE, et al., ) OPINION & ORDER ) Defendants. ) )

*** *** *** *** Just months after the Court denied Kentucky Heartwood’s (Heartwood) motion to complete the already 7,500+ page Administrative Record (Record), Heartwood maintains the Record is insufficient to reach the merits. Now, contemporaneous with the parties’ cross-motions for summary judgment, Heartwood filed three motions, each seeking, in a word, to supplement the current Record with extra-record documents and discovery. It seeks “relief under Rule 56(d),” claiming that it lacks sufficient information to defendant against summary judgment, extra-record discovery to inquire into the U.S. Forest Service’s (Service) decision not to issue a Supplemental Environmental Impact Statement, and a renewed motion to supplement the Record with additional materials obtained through the Pinyon Public folder and through FOIA requests. See DE 61; 62; 67. In overruling Heartwood’s previous motion to complete the record, the Court cautioned that “the 7,500-page record demands attention.” See DE 55 at 10. That advice, obviously, did not make it home. Because none of Heartwood’s motions meet the high standard required to disturb the certified Record, the Court DENIES these related motions, though addressing the supplementation issue distinctly. I. Relevant Background1 Heartwood’s amended complaint asserts a bevy of claims generally challenging the Service’s decision to approve the South Red Bird Wildlife Habitat Enhancement (SRB) Project. Heartwood asserts that, in approving and implementing the project, the Service violated the National Environmental Policy Act (NEPA), the National Forest Management Act (NFMA), the

Endangered Species Act (ESA), and (as the relief vehicle) the Administrative Procedures Act (APA). See DE 1 at 1–2 ¶¶ 1–2 (citing 5 U.S.C. §§ 704, 706). Heartwood later amended its complaint to include claims for the Service’s alleged failure to act under those provisions. See DE 22-1 at 71–76. To facilitate judicial review under APA § 706, the Court ordered the Service to tender the certified Record on April 21, 2023. See DE 29. The Court granted a short extension, see DE 38, and the Service then filed a 7,087-page record on April 27, 2024. See DE 36. In agreement with Heartwood, the Service added an additional 547 pages on June 1, 2023. See DE 41. The Court then set Heartwood’s deadline to file any motions to complete the Record by June 2, 2023. See DE 40.

Three days after that deadline, Heartwood filed its “Motion to Complete the Administrative Record,” seeking to add documents obtained from Pinyon Public in an online folder the Service erroneously made public, along with other documents Heartwood received from the Service and others in response to FOIA requests. See DE 43. On initial review, Judge Ingram denied the motion. See DE 50. He found that the “bad faith” standard applied to Heartwood’s motion, even if named a motion to complete rather than to supplement, and that the Service did not act in bad faith in omitting the documents. See DE 50 at 12.

1 Much of the procedural history supporting these motions mirrors Heartwood’s previous motion to complete the Record, resolved at DE 55. Accordingly, the Court offers only a brief overview here. Heartwood then objected to Judge Ingram’s Order, arguing still a purported distinction between motions to “supplement” the record and motions to “complete” the record, maintaining that the “bad-faith” standard applies only to the former category of motions. See DE 51. The Court rejected that argument, and overruled Heartwood’s objection. See DE 55. It reasoned that no purported distinction exists, under Sixth Circuit precedent, for treating a motion to complete as

distinct from a motion to supplement. See id. at 5. Practically, the two are one and the same. In keeping with that logic, the Court also rejected any attempt by Heartwood to rid the supplement standard of its bad faith moorings. The Court held that the Sixth Circuit has been “plain and direct” in setting the necessary standards for record supplementation, which require the plaintiff to show that the agency “deliberately or negligently exclude[d] certain documents, or when the court needs certain ‘background information in order to determine whether the agency considered all of the relevant factors.’” Id. at 6. In any event, there “must also be a strong showing of bad faith.” See id. Thus, the Court overruled Heartwood’s objections and affirmed Judge Ingram’s determination that Heartwood failed to identify any bad faith on the Service’s part in excluding the challenged

documents from the Record. See id. Pertinent to these motions, the Court also denied Heartwood’s request for additional briefing on the bad faith issue and cautioned that it “will not allow a further motion on the documents here at issue.” See id. at 10–11. The parties then proceeded to the dispositive motions deadline, set for June 3, 2024. See DE 58. On that day, the Service filed its motion for summary judgment, and Heartwood filed its motion, styled as a partial motion for summary judgment. See DE 60; 63. However, alongside those two motions, Heartwood filed an additional and expansive motion for a preliminary injunction, see DE 64, a motion to supplement the Record with documents and discovery and for leave to file the motion outside the Court’s scheduling order, see DE 61; 62, and a motion for relief under FED. R. CIV. P. 56(d), see DE 67. The Court focuses this inquiry on the three motions relating to the sufficiency of the Record. These three motions, though separate in name and authority, essentially allege a common goal or issue. Heartwood argues that the Record before the Court is insufficient in its current form to effectively facilitate judicial review. The mechanics of the three motions, to be sure, are different. One asks to supplement the record with existing documents.

Another asks for discovery to determine what further evidence should be added. And another asks, in part, for the Court to defer considering the merits until the Service remedies these listed deficiencies. But all embody Heartwood’s undeterred position that the Record, in its current form, does not include information that it should. Given the analytical linkage, the Court resolves the three motions together. II. Motion to Supplement Heartwood moves for the second time to add documents to the certified record, now named officially a motion to supplement, and preceded by a motion requesting leave to file. See DE 61; 62. Heartwood would have the Court add two documents to the administrative record: (1) a

“briefing paper” prepared by the Service internally analyzing objections made to the SRB project during the notice-and-comment period, see DE 62-1 at 6–52, and minutes of “Target Timber Goals Meeting[s]” spanning a three-year period obtained by Heartwood through FOIA requests. See id. at 56–116. Heartwood argues that these documents call for supplementation because the Service “deliberately withheld documents from the Court that were adverse to its position” and because the absence of documents generated by the Service in response to Heartwood’s supplemental information evinces “bad faith” on the Service’s part.2 See DE 62 at 20–25. a. Legal Standard For all the discussion to the contrary, the standard required to supplement a certified administrative record on judicial review is straightforward. The APA calls courts to “review the

whole record or those parts of it cited by a party.” 5 U.S.C. § 706.

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