Animal Legal Defense Fund v. Donna Shalala, Secretary of the Department of Health and Human Services

WALD, Circuit Judge,

concurring in the result:

The panel holds that the animal rights organizations’ (collectively, “ALDF”) appeal is “moot” because appellants “sought only to gain entry to the meetings of the Revision Committee,” Majority Opinion (“Maj. op.”) at 366, and the meetings have now ended. Because I do not think that the relief requested by appellants was so limited, I disagree with the majority’s conclusion of mootness. Nonetheless, I would affirm the denial of a preliminary injunction because, as the district court held, appellants have faded to demonstrate the required “likelihood of success on the merits.” See Washington Metropolitan Area Transit Comm’n v. Holiday Tours, Inc., 559 F.2d 841, 843 (D.C.Cir.1977) (“WMATC”).

Appellants initially requested a preliminary injunction preventing the federal defendants from “utilizing [the] Committee ... until they comply with the Federal Advisory Committee Act (‘FACA’), 5 U.S.CApp. II et seq.” Plaintiffs’ Motion for Preliminary Injunction, ALDF v. Shalala (No. 94evl003) (Oct. 14,1994), at 1-2. They enumerated the relief that they believed the district court should grant to ensure compliance with FACA, including ordering the federal appel-lees to:

1. Provide timely and complete notice of each and every future meeting of this Committee by publishing the same in the Federal Register;
2. Provide plaintiffs and the public with access to each and every meeting of the Committee ...;
3. Make available to the plaintiffs and the public records, reports, transcripts, minutes, appendices, working papers, drafts, studies, agendas, or other documents which were made available and are going to be made available to or are prepared by the Committee;
4. Provide plaintiffs and the public with detailed minutes of each meeting of the Committee that has taken place to date, and each future meeting ...;
5. Take all steps necessary to ensure that the membership of the Committee is fairly balanced....

Plaintiffs Proposed Order for Preliminary Injunction, ALDF v. Shalala (No. 94cv1003) (Oct. 14, 1994), at 2-3. The majority’s view of this case is predicated on the notion that appellants renounced the entirety of this request for relief at the hearing before the district judge — except that they be allowed “to gain entry to the meetings of the Revision Committee.” Maj. op. at 366.

My examination of the hearing transcript does not reveal sp broad a renunciation. The only relevant exchange at the hearing concerned appellants’ request that the federal appellees be required to publish a notice in the Federal Register before each meeting of the Committee. The attorney for the National Academy of Sciences (“NAS”) stated that

there are particular problems with the issuance of a preliminary injunction at this stage. The [appellants’ proposed] preliminary injunction ,., requires the publication of a notice in the Federal Register. It is going to take a couple of weeks anyway.

He opined that. the “November meeting would [therefore] have to be canceled.” Transcript of Hearing (Oct. 25, 1994), at 42-43, reprinted in Joint Appendix (“J.A.”), at 367-68. Counsel for the animal rights organizations responded:

[W]ith respect to the November meeting that’s coming up plaintiffs [propose] if your Honor is thinking of granting our motion for preliminary injunction fashioning the order in such a way ... to allow the chartering of that committee to occur’ after the committee meets but we would very much like to have that committee meeting open to the public. That way the November meeting could go forward and the process of chartering it, which is the most time-consuming part, could occur later.

*368Id. at 369-70. No more was said about the scope of relief requested by appellants.

While this statement by plaintiffs’- counsel apparently acquiesced to a preliminary injunction that would allow chartering the November meeting by publication in the Federal Register after the meeting took place, it is not susceptible to the interpretation that it rescinded appellants’ entire request for relief except insofar as permitting them to “gain entry to the meetings of the Revision Committee.” Maj. op. at 366. Moreover, the statements the majority cites from appellants in their brief and the district- court at the hearing, Maj. op. at 365 & n. 2, are entirely consistent with a less extreme construction of the exchange. Appellants stated only that “they were not seeking any relief which would preclude the Committee from meeting on November 2-4 or would in any other way disrupt the Committee’s work”; that does not mean they intended to abandon their request that the Committee provide public access to their minutes, records, reports, working papers, and other documents — as, indeed, a committee covered by FACA is affirmatively required to do in every case. See Food Chemical News v. HHS, 980 F.2d 1468 (D.C.Cir.1992). The district court did say at the hearing that appellants sought. only “public access to the meetings”; I assume, however, that the judge employed the term “access” to encompass both the public’s FACA right to be physically present at Committee meetings and its right to inspect the minutes and other documents produced by the Committee at those meetings — see FACA, 5 U.S.C.App. II § 10 (providing for both physical and documentary “access”)— since the court had appellants’ written request for both kinds of “access” before it.

I therefore conclude that appellants rescinded their request that the preliminary injunction require the federal appellees to charter the Committee in the Federal Register before the November meeting, and that their request that the preliminary injunction allow them to attend meetings that have already been held is moot.1 I believe, however, . that there remains a live controversy concerning the propriety of the district court’s denial of appellants’ request for a preliminary injunction insofar as they asked that it provide them access to the Committee’s work-product.

It is true, as the majority states, that this information will be “available to appellants should they succeed on the merits” in a final judgment. Maj. op. at 366. But of course it is almost always the case that relief requested in a preliminary injunction would later be available should the party “succeed on the merits.” The traditional question in a preliminary injunction proceeding is whether there is a critical difference between relief now and relief later — the “irreparable injury” inquiry. WMATC, 559 F.2d at 843.

In the FACA context particularly, there may be a big difference between relief now and later. As the Eleventh Circuit has stated,

[bjecause FACA’s dictates emphasize the importance of openness and debate, the timing of [public] observation and comment is crucial to compliance with the statute. Public observation and comment must be contemporaneous with the committee process itself [citation omitted]. If public commentary is limited to retrospective scrutiny, the Act is rendered meaningless.

Alabama-Tombigbee Rivers Coalition v. Dep’t of Interior, 26 F.3d 1103, 1106 (11th Cir.1994). This would appear to apply in our case. Presumably, appellants wish to let the *369sun shine in on the Revision Committee’s decisionmaking processes now, while the Committee is still “deciding,” not after the revised guide is issued, which is precisely what FACA was designed to help them do. In any event — however one might rule on the merits of the “irreparable injury” inquiry— surely the question is not “moot.”

I would nonetheless deny the appeal because I agree with the district court that appellants have failed to demonstrate the “likelihood of success on the merits” — see WMATC, 559 F.2d at 843 — necessary to obtain relief in the form of a preliminary injunction.

. After oral argument, appellants informed the panel that "the Chairman of the Committee [planned to] convene an editorial session with four members of the Committee and the Academy staff” at the end of the first week in May, 1995. Appellants’ Letter, ALDF v. Shalala, No. 94-5322 (Apr. 26, 1995) ("Letter”), at 2. FACA defines "committee” as any "committee, board, commission, council, conference, panel, task force, or other similar group, or any subcommittee or subgroup thereof." . 5 U.S.C.App. II § 3(2) (emphasis added). Appellants thus suggest that this case is not moot because a "subgroup” of the Revision Committee continues to meet "several months after NAS’s suggestion of mootness.” Letter at 2. Although this argument may indeed provide an additional reason to doubt the appeal's "mootness,” I do not reach it because I think this appeal presents a live controversy regardless of whether "committee” meetings continue to take place.