Lion Raisins Inc. v. United States Department of Agriculture

This appeal concerns the United States Department of Agriculture’s (“USDA’s”) denial .of three Freedom of Information Act (“FOIA”) requests of appellant Lion Raisins (“Lion”). Lion, a large independent handler of California raisins, is the subject of a criminal investigation because the government suspects that Lion falsified documents related to USDA inspections of its raisins. In preparation of its defense, Lion submitted FOIA requests seeking documents related to USDA raisin inspections conducted at Lion’s packing facility and the facilities of its competitors, and two internal reports related to the USDA’s investigation of Lion. USDA denied Lion’s requests pursuant to the “trade secrets” and “law enforcement” exemptions of FOIA. See 5 U.S.C. § 552 (b)(4), (7)(A). After exhausting its administrative appeals, Lion brought this action to compel production of the documents pursuant to 5 U.S.C. § 552 (a)(4)(B). The district court granted summary judgment to USDA. On appeal, Lion contends that the district court misapplied both the “trade secrets” and “law enforcement” exemptions. Lion also objects to the district court’s reliance on in camera review of the government’s sealed…