Pub. Just. Found. v. Farm Serv. Agency, No. 20-01103, 2020 U.S. Dist. LEXIS 184272 (N.D. Cal. Oct. 5, 2020)

Pub. Just. Found. v. Farm Serv. Agency, No. 20-01103, 2020 U.S. Dist. LEXIS 184272 (N.D. Cal. Oct. 5, 2020)

Re:  Requests for records concerning specific agricultural operations and geographical areas, as well as extent to which FSA considers environmental impacts before awarding federal farm loans to an applicant and extent to which FSA oversees use of funds after distribution

Disposition:  Granting in part plaintiffs' motion for summary judgment

• Litigation Considerations, Adequacy of Search:  The court "finds that FSA's search was not reasonably calculated to uncover all relevant documents."  "The agency's declaration attempting to demonstrate the contrary instead raises substantial doubt, abandons the clarifying information it requested of plaintiffs, and fails to account for positive indications of overlooked materials."  The court explains that "the agency merely points out that the original request did not include the clarifying information and states plaintiffs should have either drafted their request differently or submitted a new FOIA request."  "The agency provides no authority explaining why subsequent explanatory information from plaintiffs should not be factored into the scope of the agency's search, no less one the agency itself volunteered to perform anew."  Additionally, the court finds that "the declaration's conclusory reasons for searching the subject line of emails for the chosen search terms only address the avoidance of irrelevant material, rather than demonstrate that the search was reasonably calculated to uncover all relevant documents."