ELR Citation: 55 ELR 20055
No(s). 24-50189 (5th Cir. May 5, 2025)

The Fifth Circuit, 2-1, reversed a district court's summary judgment for the State Department in a FOIA lawsuit seeking records related to the Department's efforts to support the 2030 emissions reduction target in the Paris Agreement. A nonprofit group submitted a 10-part FOIA request, seeking recommendations, determinations, analyses, summaries, and documents provided or prepared by State Department employees, and subsequently sued, arguing the Department wrongly withheld employee names and email addresses. The Department argued it had appropriately relied on FOIA Exemption 6 to redact names and contact information for rank-and-file employees. The district court granted summary judgment, finding the Department correctly determined that "public association of a specific official with comments or edits made with the expectation of anonymity could expose the individual to unwanted and detrimental attention in the conduct of their official duties," and that there was no basis to conclude disclosing the names and email addresses "would advance the knowledge" of the process that developed the target. The appellate court found it was unnecessary to determine whether the information at issue was similar to personnel and medical files for purposes of Exemption 6, but that even if it was, its disclosure did not "constitute a clearly unwarranted invasion of personal privacy." It reversed summary judgment for the Department, rendered judgment in favor of the group as to applicability of FOIA's Exemption 6, and remanded for further proceedings.