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Food Mktg. Inst. v. Argus Leader Media
United States Supreme Court
139 S. Ct. 2356 (2019)
Argus Leader Media (Argus) (plaintiff), a newspaper publisher, submitted a Freedom of Information Act (FOIA) request to the United States Department of Agriculture (USDA) for data on the food-stamp program. Argus wanted a list of all grocery stores that participated in the program as well as food-stamp redemption data, known as store-level data, for the fiscal years 2005 to 2010. The USDA released a list of participating stores, but it did not release the store-level data, invoking exemption 4 of the FOIA. Exemption 4 allows agencies to withhold commercial information obtained from an individual that is privileged or confidential. Argus sued in federal court. The district court ruled that commercial information was considered confidential only if its disclosure would cause significant competitive harm. The district court also found that harm would be inflicted by release of the information, but that the harm would not be significant. The USDA declined to appeal but invited the Food Marketing Institute to intervene, which it did, appealing to the Eight Circuit. The Eighth Circuit affirmed. The Food Marketing Institute appealed to the Supreme Court.
Rule of Law
Holding and Reasoning (Gorsuch, J.)
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