Conservation Force v. Jewell, No. 15-5131, 2015 U.S. App. LEXIS 21128 (D.C. Cir. 2015) (per curiam)
Date
Conservation Force v. Jewell, No. 15-5131, 2015 U.S. App. LEXIS 21128 (D.C. Cir. 2015) (per curiam)
Re: Request for records concerning import permits for Canadian wood bison trophies since 2000
Disposition: Granting defendant's motion for summary affirmance
- Exemption 5, Deliberative Process Privilege, Attorney Work-Product Privilege, Attorney-Client Privilege: The Court of Appeals for the District of Columbia Circuit holds that "[t]he district court correctly determined that the documents sought by Conservation Force pursuant to the Freedom of Information Act were properly redacted by the Department of the Interior under Exemption 5 of the Act." "The Department met its burden of demonstrating that documents redacted under the deliberative process privilege reflected communications that fell within the consultative process of determining whether permits should be issued for the importation of Canadian wood bison trophies." "The Department also met its burden of demonstrating that documents redacted under the attorney work product privilege were documents created pursuant to then-pending litigation relating to the permit decisions." "In addition, the Department met its burden of demonstrating that documents redacted under the attorney-client privilege reflected confidential communications involving attorneys that related to legal strategy."
Court Decision Topic(s)
Court of Appeals opinions
Exemption 5
Exemption 5, Attorney-Client Privilege
Exemption 5, Attorney Work-Product Privilege
Exemption 5, Deliberative Process Privilege
Updated December 16, 2021