Sierra Club v. United States Environmental Protection Agency

CourtDistrict Court, N.D. California
DecidedDecember 8, 2020
Docket3:18-cv-03472
StatusUnknown

This text of Sierra Club v. United States Environmental Protection Agency (Sierra Club v. United States Environmental Protection Agency) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sierra Club v. United States Environmental Protection Agency, (N.D. Cal. 2020).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 SIERRA CLUB, Case No. 20-cv-03472-JCS

8 Plaintiff, ORDER REGARDING MOTION FOR 9 v. CLAWBACK AND SUMMARY JUDGMENT 10 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, Re: Dkt. No. 80 11 Defendant.

12 13 I. INTRODUCTION 14 This case arose from Plaintiff Sierra Club’s request for documents from Defendant the 15 Environmental Protection Agency (the “EPA”) under the Freedom of Information Act (“FOIA”). 16 Most of the parties’ disputes have been resolved by the Court or by the parties’ themselves, and 17 the EPA has produced a large number of documents to Sierra Club. Among those documents was 18 a series of emails exchanged among an EPA employee, a White House official, and several 19 individuals who work in government affairs—in other words, as lobbyists—for the petroleum 20 industry, discussing plans to meet for drinks. The EPA inadvertently produced those emails 21 without redacting all instances of the lobbyists’ names and email addresses. The only remaining 22 dispute in the case is the EPA’s present motion to claw back the documents lacking those intended 23 redactions. 24 The Court finds the matter suitable for resolution without oral argument and VACATES 25 the hearing previously set for December 11, 2020. For the reasons discussed below, the EPA’s 26 motion is DENIED.1 27 1 II. BACKGROUND 2 The emails at issue included Jeff Freeland (a Special Assistant to the President), Aaron 3 Ringel (at the time, an EPA official),2 and individuals whose names are not included in the record 4 before the Court, but whose email addresses use the domain names of Valero, Marathon 5 Petroleum, and the trade association American Fuel and Petrochemical Manufacturers. White 6 Decl. (dkt. 80-1) Ex. 1. According to the EPA, those individuals “held mid-level management 7 positions in the government relations departments of these organizations.” White Decl. ¶ 4. The 8 emails discuss plans to meet for drinks and to watch a hockey game, using a consistently informal 9 tone suggesting that all individuals involved were friends. While Decl. Ex. 1. The emails do not 10 indicate that the gathering would be for any purpose other than socializing; to the contrary, the 11 Marathon Petroleum employee expressed interest in joining only “as long as we don’t talk about 12 RFS” (presumably, the EPA’s “renewable fuel standards” program), to which Ringel and the 13 Valero employee quickly and enthusiastically agreed. See id. 14 Sierra Club submitted a wide-ranging request under FOIA for communications by a 15 number of EPA officials, including Ringel, with any person outside of the EPA. See Order 16 Granting Pl.’s Mot. for Partial Summ. J. (dkt. 39) at 1–2.3 Sierra Club selected those officials 17 based on its view that they “have a history of close ties with industries regulated by EPA or anti- 18 environmental politicians or political groups.” Opp’n (dkt. 81) at 2. The EPA initially withheld 19 the emails now at issue entirely, but after Sierra Club filed this action, the Court ordered 20 production of documents, and the parties conferred regarding their disagreements, the EPA 21 produced the emails with many names, email addresses, locations, and other details redacted based 22 on FOIA’s Exemption 6, governing personal privacy. Stip. (dkt. 78) at 2. The EPA inadvertently 23 failed to redact all instances of the petroleum lobbyists’ names and all instances of the first 24 portions their email addresses4 in that production of documents. Id.; see also White Decl. Ex. 1 25 was reassigned to the undersigned magistrate judge upon Judge Laporte’s retirement. 26 2 Ringel now works for the Department of State, which also deals with matters affecting the oil industry. Saxonhouse Decl. (dkt. 81-1) ¶ 10. 27 3 Sierra Club v. U.S. Envtl. Prot. Agency, No. 18-cv-03472-EDL, 2018 WL 10419238 (N.D. Cal. 1 (copies of the emails with additional redactions added to obscure the information presently in 2 dispute). Sierra Club’s counsel circulated the emails to “internal stakeholders within Sierra Club,” 3 and requested that the EPA disclose additional names and email addresses based on its failure to 4 redact some such information. Stip. at 2. That request caused the EPA to realize that it had failed 5 to redact the emails as intended, and the EPA informed Sierra Club of the error and provided 6 corrected versions with further redactions. Id. 7 Sierra Club “agreed as a courtesy to not further share the inadvertently produced 8 documents until the dispute over them was resolved.” Id. The parties were unable to resolve their 9 disagreement as to whether the information at issue was properly subject to withholding under 10 FOIA, and Sierra Club took the position that it need not seek an order for production of the 11 material because it already possessed the information and saw no “legal or ethical barriers to 12 releasing the information should it come up.” Id. at 2–3. After Sierra Club informed the EPA that 13 Sierra Club would not agree to keep the information confidential indefinitely if no ruling was 14 sought from the Court, the EPA filed the present motion. Id. at 3. 15 In its production of separate emails more clearly addressing the EPA’s official business, 16 the EPA did not redact the names or email addresses of petroleum lobbyists. See Zack Decl. (dkt. 17 80-3) Exs. A–C. The EPA has also released other emails containing the names and email 18 addresses of non-government employees who corresponded with EPA personnel on matters 19 unrelated related to EPA business. Saxonhouse Decl. (dkt. 81-1) Exs. A, B.5 20 The EPA now moves for an order requiring Sierra Club to destroy the emails inadvertently 21 produced with incomplete redactions. See Mot. (dkt. 80) at 12. The EPA contends that the 22 lobbyists’ names and email addresses fall within Exemption 6 because the lobbyists have a 23

24 address, which indicate the lobbyists’ employers. 5 While the EPA asserts in its reply that some of those emails included more senior EPA 25 policymakers and some involved official business, Reply (dkt. 82) at 3, at least some of the emails plainly related to personal matters. See, e.g., Saxonhouse Decl. Ex. B at ECF p. 27 (email from an 26 EPA Deputy Assistant Administrator asking an ExxonMobil employee to provide career counseling for a friend, with the name and email address of the ExxonMobil employee 27 unredacted); id. at ECF pp. 21–22 (emails between an EPA Assistant Administrator and non-EPA 1 nontrivial privacy interest in that sort of personal information and there is no significant public 2 interest in learning which individuals had been planning the happy hour. Id. at 7–11. Elizabeth 3 White, director of the EPA office responsible for FOIA requests, states that Sierra Club has in the 4 past provided records it obtained under FOIA to the press, and that “disclosure would expose these 5 individuals to potential harassment from the media or potential harassment from individual 6 actors.” White Decl. ¶ 5. White notes that “[o]nline harassment or ‘doxxing’ is a reality,” citing 7 articles describing generally the practice of disseminating personal information to facilitate 8 targeted harassment, but not linking that practice to Sierra Club disclosures, and providing no 9 evidence or explanation of why the lobbyists at issue might be expected to receive such treatment. 10 See id. ¶ 5 & n.3. The EPA cites a handful of district court decisions ordering FOIA plaintiffs to 11 return or destroy inadvertently produced documents based on those courts’ inherent authority. 12 Mot. at 11–12. 13 Sierra Club contends that Exemption 6 does not apply because the public interest in 14 understanding government regulators’ relationships with industry lobbyists outweighs any de 15 minimis privacy interest in the lobbyists’ names, and because the EPA has not shown any non- 16 speculative risk of harm from disclosure. Opp’n at 6–12.

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Sierra Club v. United States Environmental Protection Agency, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sierra-club-v-united-states-environmental-protection-agency-cand-2020.