Recently a U.S. Federal District Court ruled that the U.S. Environmental Protection Agency (EPA) could turn over publically gathered data on concentrated animal feeding operations (CAFO) to three environmental groups. American Farm Bureau and National Pork Producers Council (“Plaintiffs”) had expressed concerns the disclosure would violate privacy rights of their members. The district court found the Plaintiffs had no standing to bring the claim.
American courts have had a long tradition of only hearing cases where the parties can demonstrate imminently to be harmed by a law. This means having legally protectable interest in the dispute; this is also known as “standing.” For example, you and your neighbor are having a property line dispute. You and your neighbor would have standing in any dispute involving the property line, but a property owner a mile away would not have standing in a property line dispute between you and your neighbor.
To find standing, courts often require the parties to meet three requirements:
1. The party has an injury-in-fact – the party has suffered or will imminently suffer an injury to a legally protected interest. The injury cannot be hypothetical or abstract.
2. The causation relationship between the injury and the defendant’s action is being challenged.
3. It must be likely that the injury can be solved by a favorable decision and not merely speculative.
A party demonstrating all three of these elements will have standing to bring a claim in court.
In this case, the court found that the Plaintiffs failed to demonstrate that EPA’s turning over the public information would cause Plaintiffs’ members to lose control of their personal information. The personal information at issue here had been gathered by EPA from public sources in order to better identify and inspect CAFOs nationwide. Much of the information EPA had gathered was required to be publically disclosed under Federal and state laws to better engage the public in the Clean Water Act. Releasing this public information did not establish an injury for standing purposes in the court’s mind.
Plaintiffs also failed to prove an injury. Although Plaintiffs had testimony of members discussing concerns of being the victims of tactics from activist groups, this was not enough to prove an injury due to EPA’s actions. Possible injuries would come from third parties and not EPA.
Finally, a favorable court decision solving the Plaintiffs’ injury (information being release) was speculative in the court’s mind. The information which the Plaintiffs were seeking to stop EPA from releasing was already publically available and preventing EPA from releasing it would not take it out of the public realm. The court dismissed Plaintiffs’ lawsuit.
Constitutional standing is important even when dealing with agricultural law issues. Requiring a party to have standing before the court allows the court to exercise judicial authority to settle the dispute. In this case, the court found that it did not have the authority.
There are a couple of important notes on this case. The decision was from the U.S. Federal District Court of Minnesota and only involves information from CAFOs in Minnesota and Iowa. Plaintiffs have already begun the appeal process before the U.S. Court of Appeals for the Eighth Circuit. The outcome of this case could change on appeal. A copy of the opinion is available here. You can follow the appeals process on American Farm Bureau Federation’s Legal Advocacy page dedicated to this case here.
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