UtahAmerican Energy, Inc. v. Dep’t of Labor

UtahAmerican Energy brought this action against the Department of Labor under FOIA, seeking documents related to government investigations of a collapse at one of its mines. The district court ruled in favor of UtahAmerican on the disputed exemptions and ordered it to produce documents covered by those exemptions. The court also ordered the Department to produce documents that were the subject of an earlier-filed FOIA suit that was pending before another district court. The Department appealed. The D.C. Circuit Court of Appeals (1) dismissed as moot those portions of the appeal that related to Exemption 7(A) because the Department's basis for asserting that exemption has disappeared, thus requiring it to produce many of the contested documents that were protected by 7(A) alone; (2) reversed the district court insofar as it directed the Department to certain documents that were protected by Exemption 7(C); and (3) reversed the district court's judgment with respect to the documents subject to the earlier FOIA suit, holding that the court should have left disposition of the balance of the remaining documents to the court hearing the earlier-filed suit. Remanded. View "UtahAmerican Energy, Inc. v. Dep't of Labor" on Justia Law