Montrose Chemical Corporation of California v. Train
United States Court of Appeals for the District of Columbia Circuit
491 F.2d 63 (1974)
The Environmental Protection Agency (EPA) conducted hearings under the Federal Insecticide, Fungicide, and Rodenticide Act about the insecticide DDT and registrations to use DDT. The hearings produced over 9,000 pages of records. The hearing examiner determined that all DDT registrations had complied with the law. Rather than letting an appeal from the hearing examiner go to a judicial officer, the EPA administrator (defendant) withdrew the case for review by himself and three additional EPA officials. To assist with his review, the EPA administrator asked the three additional EPA officials to review the public record and create summaries of the facts introduced at the hearings. The officials created two documents summarizing the facts. The EPA administrator reversed the hearing officer, releasing a 50-page opinion holding that certain DDT registrations were unlawful and ordering their cancellation. Montrose Chemical Corporation of California (Montrose) (plaintiff) filed a lawsuit in federal district court against the EPA administrator under the Freedom of Information Act (FOIA), seeking disclosure of the two documents created by the EPA officials. FOIA required the government to make its records public upon request. The EPA argued that the documents were exempt from FOIA under the deliberative-process exemption codified at 5 U.S.C. § 552(b)(5) because the documents were created as part of the agency’s internal deliberations. The district court ordered the EPA to disclose the documents. The EPA appealed.
Rule of Law
Holding and Reasoning (Wilkey, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 710,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 710,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 44,600 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.