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Zanoni v. U.S. Dep’t of Agriculture – Case Brief Summary (Federal Court)

In Zanoni v. U.S. Dep't of Agriculture, 605 F.Supp.2d 230, 232 (D.D.C. 2009), the plaintiff submitted a Freedom of Information Act ("FOIA") request to the Animal Plant Health Inspection Service regarding ". . . all records of registered premises contained in databases, including the name of the entity, name of contact person, address, telephone number, . . ., and type of operation run on the premises." Id. at 233.

The U.S. Department of Agriculture ("Agriculture Department") denied her request, alleging that FOIA exempted the documents from disclosure. Id.

The plaintiff filed a complaint in the U.S. District Court, and the Court ordered that the Agriculture Department respond to the plaintiff's request. See id. at 234.

The U.S. Department provided the entities' names, but did not disclose any further information. Id. Subsequently, both parties filed motions for summary judgment. Id.

The U.S. District Court examined the organic statute, which provided:

Any officer or employee of the U.S. Department of Agriculture . . . shall not disclose . . . information provided by an agricultural producer or owner of agricultural land concerning the agricultural operation, farming or conservation practices, or the land itself, in order to participate in programs of the U.S. Department. Id. at 236.

The Court determined that the information sought concerned an "agricultural operation, farming . . . or the land itself," as it related to ". . . the production and marketing of agricultural commodities and livestock.'" Id. at 237.

Hence, the request was properly denied. Id. at 238.