Argus Leader Media v. United States Department of Agriculture
740 F.3d 1172
8th Cir.2014Background
- Argus Leader requested annual EBT redemption amounts (store-level SNAP spending) for fiscal years 2005–2010 from USDA under FOIA.
- USDA provided retailer names/addresses but withheld aggregated spending/redemption data, invoking FOIA Exemption 3 and 7 U.S.C. § 2018(c).
- Argus administratively appealed and then sued in federal court to compel disclosure under 5 U.S.C. § 552(a)(4)(B).
- The district court granted summary judgment to USDA, holding § 2018(c) is an Exemption 3 withholding statute and that the redemption data fell within its protection.
- The Eighth Circuit reviewed de novo, focusing on whether § 2018(c)’s text covers information “obtained under” that subsection (i.e., information “submitted by applicants”).
- The court held the redemption/spending data was generated from third-party processors, not “submitted by” retailers or tax filings, so § 2018(c) does not exempt that data from FOIA; it reversed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether retailer-level SNAP redemption/spending data is exempt from FOIA under Exemption 3 via 7 U.S.C. § 2018(c) | Argus: Data is not "submitted by applicants" or a tax filing; it is government-held information and thus disclosable under FOIA. | USDA: § 2018(c) (and Exemption 3) covers “any information... obtained under” that subsection, including redemption data used to determine eligibility, so withholding is required. | The court held § 2018(c) protects only information submitted by applicants (e.g., tax filings); redemption data obtained from third-party processors is not covered, so Exemption 3 does not apply. |
Key Cases Cited
- Mo. ex rel. Garstang v. U.S. Dep’t of Interior, 297 F.3d 745 (8th Cir. 2002) (standard of review for FOIA summary judgment)
- Miller v. U.S. Dep’t of State, 779 F.2d 1378 (D.C. Cir. 1985) (agency bears burden to show full compliance with FOIA)
- Nat’l Cable Television Ass’n v. FCC, 479 F.2d 183 (D.C. Cir. 1973) (agency must account for each requested document)
- United States v. Gonzales, 520 U.S. 1 (1997) (statutory interpretation begins with text)
- FBI v. Abramson, 456 U.S. 615 (1982) (FOIA exemptions construed narrowly)
- Barnhart v. Sigmon Coal Co., 534 U.S. 438 (2002) (courts presume legislature means what it says)
- Dep’t of Air Force v. Rose, 425 U.S. 352 (1976) (FOIA’s purpose is to open agency action to public scrutiny)