Southern Environmental Law Center v. Tennessee Valley Authority

CourtDistrict Court, E.D. Tennessee
DecidedFebruary 13, 2025
Docket3:24-cv-00097
StatusUnknown

This text of Southern Environmental Law Center v. Tennessee Valley Authority (Southern Environmental Law Center v. Tennessee Valley Authority) 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, (E.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE

SOUTHERN ENVIRONMENTAL ) LAW CENTER, ) ) Plaintiff, ) ) v. ) No.: 3:24-CV-97-TAV-DCP ) TENNESSEE VALLEY AUTHORITY, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER

This civil matter is before the Court on defendant’s Motion for Partial Dismissal for Lack of Subject Matter Jurisdiction [Doc. 19]. Plaintiff responded [Doc. 25] and defendant replied [Doc. 28]. Plaintiff filed two supplemental briefs [Docs. 29, 31] pursuant to Local Rule 7.1(d), alerting the Court to related case developments. Defendant responded to the first of these briefs [Doc. 30] and the time for responding to the second has passed. See E.D. Tenn. L.R. 7.1(d). Accordingly, this matter is ripe for resolution. See E.D. Tenn. L.R. 7.1(a). For the reasons explained below, the Court will DENY defendant’s Motion for Partial Dismissal for Lack of Subject Matter Jurisdiction [Doc. 19]. I. Background This case arises from plaintiff’s Freedom of Information Act (“FOIA”) requests regarding the Cumberland Fossil Plant managed by the Tennessee Valley Authority (“TVA”) [Doc. 1 ¶¶ 1–2]. Plaintiff seeks declaratory and injunctive relief, alleging that defendant failed to comply with FOIA requirements in responding to its requests [Id. ¶¶ 3–4]. Plaintiff submitted three separate FOIA requests in December 2022, March 2023, and April 2023 [Id. ¶¶ 24–38]. As of February 29, 2024, the date on which plaintiff filed suit, defendant had not provided records responsive to any of these three requests [Id. ¶¶ 27, 34, 38]. In its complaint, plaintiff asserts that it constructively exhausted its administrative

remedies because, at that time, defendant had failed to make any determination on its FOIA requests within the statutorily prescribed period [Id. ¶¶ 39–46]. See 5 U.S.C. §§ 552(a)(6)(A)(i), (a)(6)(C)(i). After plaintiff filed suit, defendant provided records responsive to the first and third FOIA requests.1 Specifically, on March 14, 2024, defendant responded to plaintiff’s

December 2022 request, and on April 3, 2024, defendant responded to plaintiff’s April 2023 request [Docs. 18-1–2]. On April 8, 2024, defendant filed the instant motion [Doc. 19], seeking dismissal as to Counts One and Three under Federal Rules of Civil Procedure 12(h)(3) and/or 12(c) due to its post-filing responses. II. Standard of Review

Federal Rule of Civil Procedure 12(h)(3) provides that “[i]f the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.” Federal courts can adjudicate only those claims that are within the judicial power of the United States as defined in the Constitution and that have been entrusted to them by a jurisdictional grant of Congress. Chase Bank USA, N.A. v. City of Cleveland, 695 F.3d

1 Defendant acknowledges that its response to plaintiff’s second FOIA request is forthcoming and therefore does not move for dismissal of Count Two, which alleges FOIA violations related to plaintiff’s March 2023 request [Doc. 20, p. 3 (“Only the first and third FOIA requests are at issue on this motion.”)]. 2 548, 553 (6th Cir. 2012). “A motion to dismiss brought under Rule 12(h)(3) is analyzed in the same manner as a motion to dismiss brought under Rule 12(b)(1).” Tubbs v. Long, No. 3:20-CV-477, 2022 WL 508895, at *3 (M.D. Tenn. Feb. 17, 2022), aff’d, No. 22-5127,

2022 WL 13983800 (6th Cir. Oct. 24, 2022) (quoting Cohan v. MGM Hosp., Inc., No. 20-CV-10981, 2021 WL 4478744, at *1 (E.D. Mich. Sept. 30, 2021)) (citing Berkshire Fashions, Inc. v. M.V. Hakusan II, 954 F.3d 874, 879 n.3 (3d Cir. 1992)). “The distinction between a Rule 12(h)(3) motion and a Rule 12(b)(1) motion is simply that the former may be asserted at any time and need not be responsive to any pleading of the other party.” Id.

(quoting Cohan, 2021 WL 4478744, at *1) (citing Berkshire Fashions, 954 F.3d at 879 n.3). Where a Rule 12(c) motion is premised on an alleged lack of subject matter jurisdiction, the motion “merely serve[s] as an auxiliary device.” 5C Charles A. Wright & Arthur R. Miller, Federal Practice and Procedure § 1367 3d ed. (2024). When evaluating a so-called factual attack to subject matter jurisdiction, as in

defendant’s instant motion [see Doc. 20, p. 6 (“As a matter of fact, this Court lacks subject matter jurisdiction”)], the Court can weigh evidence to confirm the existence of the factual predicates for subject matter jurisdiction. Carrier Corp. v. Outokumpu Oyj, 673 F.3d 430, 440 (6th Cir. 2012). Unlike a facial attack, wherein a district court must accept the allegations of the complaint as true, “no presumptive truthfulness applies to the complaint’s

allegations; instead, the court must weigh the conflicting evidence to arrive at the factual predicate that subject-matter jurisdiction does or does not exist.” Tubbs, 2022 WL 508895, at *3 (quoting Gentek Bldg. Prods., Inc. v. Sherman-Williams Co., 491 F.3d 320, 330 (6th 3 Cir. 2007)). “[T]he district court has considerable discretion in devising procedures for resolving questions going to subject matter jurisdiction[.]” Id. (quoting Ohio Nat. Life Ins. Co. v. United States, 922 F.2d 320, 327 (6th Cir. 1990)).

III. Analysis Defendant argues that the Court lacks subject matter jurisdiction over Counts One and Three because it “fully” responded to each of plaintiff’s underlying FOIA requests after the filing of this suit [Doc. 20, p. 6]. Specifically, defendant contends that its responses to plaintiff have rendered these Counts moot in their entirety, thereby depriving

the Court of the ability to grant meaningful relief [Id. at 6–7]. In support, it cites federal cases in which claims or parts of claims were deemed moot after an agency produced responsive documents during the pendency of litigation [Id. at 7–8]. Plaintiff responds that it explicitly alleged in its complaint that defendant failed to conduct an adequate search for documents and improperly withheld records that are

non-exempt under FOIA; therefore, it contends that the Court retains subject matter jurisdiction over these unresolved issues [Doc. 25, pp. 2, 6]. Plaintiff cites case law supporting the proposition that federal courts typically retain jurisdiction in instances where an agency has produced some, but not all, of the requested documents [Id. at 5]. Additionally, it alleges several examples of potential deficiencies in defendant’s responses,

including the lack of information about the scope of its search for records, “conclusory” explanations for certain invoked exemptions, and improperly redacted material that may have been reasonably segregable from exempt material [Id. at 6–7]. 4 In reply, defendant argues that plaintiff’s allegations regarding the adequacy of its responses are premature because they have not been properly exhausted through administrative remedies [Doc. 28, p. 1]. Specifically, it contends that exhaustion of these

remedies is a jurisdictional requirement in FOIA cases; so, its responses to plaintiff after the filing of this suit have deprived the Court of jurisdiction as to Counts One and Three [Id. at 2–3]. Additionally, it argues that the pleadings are bereft of plaintiff’s specific allegations regarding defendant’s improper withholdings or redactions [Id. at 4].

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Southern Environmental Law Center v. Tennessee Valley Authority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/southern-environmental-law-center-v-tennessee-valley-authority-tned-2025.