Southern Environmental Law Center v. Tennessee Valley Authority; Tennessee Gas Pipeline Company, LLC

CourtDistrict Court, E.D. Tennessee
DecidedJanuary 12, 2026
Docket3:24-cv-00110
StatusUnknown

This text of Southern Environmental Law Center v. Tennessee Valley Authority; Tennessee Gas Pipeline Company, LLC (Southern Environmental Law Center v. Tennessee Valley Authority; Tennessee Gas Pipeline Company, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Southern Environmental Law Center v. Tennessee Valley Authority; Tennessee Gas Pipeline Company, LLC, (E.D. Tenn. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE

SOUTHERN ENVIRONMENTAL LAW ) CENTER, ) ) Plaintiff, ) ) v. ) No. 3:24-CV-00110-JRG-DCP ) TENNESSEE VALLEY AUTHORITY, ) ) Defendant, ) ) TENNESSEE GAS PIPELINE COMPANY, LLC ) ) Intervenor-Defendant. )

MEMORANDUM OPINION AND ORDER In this action under the Freedom of Information Act, 5 U.S.C. § 552 (“FOIA”), Plaintiff Southern Environmental Law Center (“SELC”) seeks to compel the release of records that it requested from Defendant Tennessee Valley Authority (“TVA”). Now before the Court are cross motions for summary judgment filed by SELC, TVA, and Intervenor-Defendant Tennessee Gas Pipeline Company, LLC (“Tennessee Gas”). [P.’s Mot., Doc. 40; TVA’s Mot. Doc. 42; Tennessee Gas’s Mot., Doc. 45]. As discussed below, the parties’ motions will be GRANTED in part and DENIED in part. I. BACKGROUND On July 7, 2023, Plaintiff submitted a FOIA request to TVA, seeking records related to a proposed gas pipeline. Specifically, SELC requested, [r]ecords of communications, including all attachments thereto, with Tennessee Gas Pipeline, Kinder Morgan, Texas Eastern Transmission, East Tennessee Natural Gas, or Enbridge regarding possible or planned energy or gas infrastructure projects, including pipelines, compressor stations, gas plants, and battery storage systems to be constructed partially or entirely in Cheatham County, Tennessee after July 2023.

[FOIA Request, Doc. 1-1 at 1]. SELC asked that the temporal scope of the search include “records created or received beginning August 2020 through the date of the search for responsive records.” [Id.]. After a conversation with TVA’s FOIA Officer, Julia Denise Smith, SELC agreed to narrow the request to include only records of communications with Kinder Morgan. [See Interim Resp. Letter, Doc. 1-3]. On August 4, 2023, Ms. Smith sent Plaintiff an interim response letter, explaining that SELC’s FOIA request had been placed in “Track 3” of its multi-track system, which is reserved for requests that are expected to take the longest time to process. [Id.]. TVA had not yet processed SELC’s request when, on March 7, 2024, SELC filed the instant lawsuit. [Compl., Doc. 1 ¶ 36]. In the Complaint, SELC alleged that TVA violated the FOIA by failing to make a determination, conduct a reasonable search, and provide SELC with all non-exempt records responsive to its FOIA request. [Id. ¶ 50]. On April 12, 2024, TVA issued a determination letter with a link to 21 responsive documents, some of which had been redacted pursuant to FOIA Exemptions 4 and 6. [FOIA Resp., Doc. 15-1 at 1]. According to the letter, seven documents were withheld in full, also pursuant to Exemptions 4 and 6. [Id. at 2]. On April 15, 2024, TVA filed a motion to dismiss for lack of subject matter jurisdiction, arguing that the lawsuit was moot because TVA had “fully responded” to SELC’s request. [TVA’s

Mot. to Dismiss, Doc. 16]. SELC opposed the motion, asserting that outstanding issues remained about the adequacy of the search and TVA’s assertions of exemptions. [P.’s Resp. Mot. Dismiss, Doc. 21 at 5–8]. The Court agreed and denied the motion. [Order, Doc. 28 at 5, 6]. After the Court denied TVA’s motion to dismiss, Tennessee Gas, whose parent company is Kinder Morgan, filed a motion to intervene under Rule 24 of the Federal Rules of Civil Procedure. [Doc. 34]. The Court granted the motion, finding that Tennessee Gas has a substantial legal interest in protecting confidential business information that may be contained in records responsive to the FOIA request. [Doc. 37].

On March 19, 2025, TVA sent SELC a supplemental FOIA response. [Supp. FOIA Resp., Doc. 41-1]. In the supplemental response letter, Ms. Smith advised that since its April 2024 response, TVA had “conducted an additional search to supplement that initial search.” [Id. at 1]. Smith explained that “the Cheatham County project was initially referred to as Ashland City, and some of the emails with that reference were inadvertently overlooked.” [Id.]. However, in the additional search, “[t]hat oversight was corrected, and two additional custodians were added, resulting in additional records.” [Id.]. The supplemental response included a link to 73 responsive records, which “comprise[d] all responsive records resulting from both the initial and supplemental searches.” [Id.]. A total of 11 documents were released in full; 62 records were released with

redactions; and 37 documents were withheld in full. [Id.]. Ms. Smith asserted that the redactions and withheld documents were justified under FOIA Exemptions 4 and 6. [Id. at 2–3]. The parties subsequently filed cross motions for summary judgment, which are now before the Court. This matter is ripe for review. II. DISCUSSION The Freedom of Information Act promotes government transparency by providing a “statutory right of public access to documents and records held by federal agencies.” Citizens for Responsibility & Ethics in Wash. (CREW) v. United States DOJ, 602 F. Supp. 2d 121, 123 (D.D.C. 2009) (citation and internal quotation marks omitted); see also NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214, 242 (1978) (explaining that FOIA’s fundamental purpose is to “ensure an informed citizenry, vital to the functioning of a democratic society, needed to check against corruption and to hold the governors accountable to the governed.”). Under the statute, “an agency must disclose all records requested by ‘any person,’ 5 U.S.C. § 552(a)(3), unless the information sought falls within one of the nine enumerated exemptions listed in section 552(b).” Vaughn v.

United States, 936 F.2d 862, 865 (6th Cir. 1991). Federal courts have jurisdiction to review de novo an agency’s withholding of records and to “order the production of any agency records improperly withheld.” 5 U.S.C. § 552(a)(4)(B). Because most FOIA challenges involve purely legal questions, district courts typically resolve these cases on summary judgment. ACLU of Mich. v. FBI, 734 F.3d 460, 465 (6th Cir. 2013). Under Rule 56 of the Federal Rules of Civil Procedure, summary judgment is proper if there is no genuine dispute as to any material fact and the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a). An agency is entitled to summary judgment in a FOIA action if no material facts are genuinely disputed and the agency shows “that its search for responsive

records was adequate, that any exemptions claimed actually apply, and that any reasonably segregable non-exempt parts of records have been disclosed after redaction of exempt information.” Competitive Enter. Inst. v.

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