Maricopa Audubon Soc'y v. U.S. Forest Serv.

ELR Citation: ELR 20842
No(s). 95-16919 (9th Cir. Mar 7, 1997)

The court holds that exemption 2 of the Freedom of Information Act (FOIA) does not exempt the U.S. Forest Service from disclosing documents revealing the locations of northern goshawk nest sites. The government has failed to demonstrate how the nest sites related "solely," or even predominantly, "to...

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