TC Company v. United States Forest Service

CourtDistrict Court, D. New Mexico
DecidedDecember 31, 2024
Docket1:23-cv-00514
StatusUnknown

This text of TC Company v. United States Forest Service (TC Company v. United States Forest Service) is published on Counsel Stack Legal Research, covering District Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
TC Company v. United States Forest Service, (D.N.M. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

TC COMPANY,

Plaintiff,

vs. No. 1:23-cv-0514 DLM/JMR

UNITED STATES FOREST SERVICE,

Defendant.

MEMORANDUM OPINION AND ORDER GRANTING THE UNITED STATES FOREST SERVICE’S MOTION FOR SUMMARY JUDGMENT (DOC. 49) AND DENYING TC COMPANY’S MOTION FOR SUMMARY JUDGEMENT (DOC. 50)1 In January and February of 2022, the United States Forest Service (USFS) conducted planned burning of debris left over from projects that involved the thinning or cutting of forest trees. The USFS refers to the planned burnings during this period as the Pino West Prescribed Pile Burn. These piles of burning debris were later covered by snow. On April 22, 2022, high winds blew off the snow, and the still-smoldering burn piles under the snow ignited, resulting in a wildfire that the USFS labeled the Cerro Pelado Fire. These events are the subject of this lawsuit. Plaintiff TC Company (TC) made requests for information on the Cerro Pelado Fire from the USFS under the Freedom of Information Act (FOIA). In its response to Plaintiff’s requests, TC contends the USFS improperly withheld agency records, while the USFS argues it conducted a reasonable search and produced all responsive documents. The parties have filed opposing motions for summary judgment, with the USFS’s motion for summary judgment consisting of fourteen undisputed material facts (UMF) supported by three exhibits. (See Docs. 49, 49-1 to -3.) TC’s

1 Under 28 U.S.C. § 636(c) and Rule 73(b) of the Federal Rules of Civil Procedure, the parties have consented to me serving as the presiding judge and entering final judgment. (Doc. 6.) motion for summary judgment consists of seventy UMFs supported by 38 exhibits.2 (See Docs. 50, 50-1 to -38.) Having reviewed the parties’ submissions and the relevant law, the Court will GRANT the USFS’s motion for summary judgment and DENY TC’s summary judgment motion. I. Legal Standard In FOIA litigation, as in all civil cases, summary judgment is granted when the movant

“shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). Substantive law determines “which facts are material[, and o]nly disputes over facts that might affect the outcome of the suit under the governing law will properly preclude the entry of summary judgment.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). The moving party bears the burden to show that there are no genuine disputes of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). Upon a proper FOIA request, federal agencies must disclose records to a member of the public. See 5 U.S.C. § 552. And an agency has a duty to construe FOIA requests liberally. See Beagles v. U.S. Dep’t of Labor Wage & Hour Div., No. CV 16-506 KG/CG, 2019 WL 1085170, at

*5 (D.N.M. Mar. 7, 2019) (citations omitted); see also Trentadue v. Integrity Comm., 501 F.3d 1215, 1226 (10th Cir. 2007) (“FOIA is to be broadly construed in favor of disclosure.”) (citation omitted). An agency also has an obligation to conduct a search “reasonably calculated to uncover all relevant documents.” US Right to Know v. Nat’l Nuclear Sec. Admin., 721 F. Supp. 3d 1198, 1205 (D.N.M. 2024) (quoting Weisberg v. U.S. Dep’t of Justice, 705 F.2d 1344, 1351 (D.C. Cir.

2 D.N.M.LR-Civ. 10.5 limits the number of pages for motion exhibits to fifty. In an apparent effort to comply with the Rule, TC formatted multiple pages of letters and documents to appear as one page in its exhibits. (See Docs. 50-4, 50- 10, 50-11, 50-20, 50-23, 50-31, 50-32, 50-34, and 50-38.) While D.N.M.LR-Civ. 10.5 provides that multiple pages of a deposition transcript may be condensed to one page, the Rule does not contemplate that a party can simply reformat multiple entire pages of documents to show as one page. Thus, TC’s exhibits run afoul of 10.5. Additionally, many of TC’s exhibits are not marked in a way that would bring specific portions of the exhibit to the Court’s attention as required by D.N.M.LR-Civ. 10.6. Nevertheless, the Court has reviewed all of TC’s exhibits but reminds counsel that in the future they should comply with the Local Rules. 1983)). In determining whether a document search was reasonable, “the issue is not whether any further documents might conceivably exist but rather whether the government’s search for responsive documents was adequate.” Trentadue v. Integrity Comm., 572 F.3d 794, 797 (10th Cir. 2009) (quoting Weisberg, 705 F.2d at 1351 (emphasis in original)). Put another way, “the focal point of the judicial inquiry is the agency’s search process, not the outcome of its search.” Id.

FOIA determinations are usually resolved at the summary judgment stage, Beagles, 2019 WL 1085170, at *4, with courts reviewing an agency’s decision de novo. 5 U.S.C. § 552(a)(4)(B); see also Hamilton v. United States, No. CIV 14-0040 KBM/GBW, 2015 WL 12696083, at *2 (D.N.M. Mar. 5, 2015) (noting that de novo review requires “all underlying facts and inferences are analyzed in the light most favorable to the FOIA requester.”). Courts do, however, “accord substantial weight to an affidavit [or declaration] of an agency concerning the agency’s determination as to technical feasibility . . . and reproducibility.” 5 U.S.C. § 552(a)(4)(B). A court may award summary judgment based on information provided by an agency in a declaration, so long as the declaration is “sufficiently detailed and non-conclusory and demonstrate[s] that the

search method was reasonably conducted to uncover all relevant documents.” Hamilton, 2015 WL 12696083, at *3 (citing Oglesby v. U.S. Dep’t of the Army, 920 F.2d 57, 68 (D.C. Cir. 1990)). An agency’s declarations are also given “a presumption of good faith, which cannot be rebutted by ‘purely speculative claims about the existence and discoverability of other documents.’” Id. (citing Judicial Watch, Inc. v. U.S. Dep’t of Justice, 185 F. Supp. 2d 54, 63 (D.D.C. 2002)) (quoting SafeCard Servs., Inc. v. S.E.C., 926 F.2d 1197, 1200 (D.C. Cir. 1991)). II. Undisputed Material Facts TC does not dispute any of the USFS’s undisputed material facts, (Doc. 55 at 6), and puts forth thirteen UMFs, which are the same or substantially similar to the USFS’s undisputed material facts. (Doc. 50 UMFs ¶¶ 1–6, 9–10, 15, 21, 24, 27, 43.) Thus, the Court accepts all fourteen of the USFS’s undisputed material facts and all thirteen of TC’s corresponding undisputed material facts. (Docs.

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Anderson v. Liberty Lobby, Inc.
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TC Company v. United States Forest Service, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tc-company-v-united-states-forest-service-nmd-2024.