Forest Service Employees for Environmental Ethics v. United States Forest Service

O’SCANNLAIN, Circuit Judge:

We are called upon to decide whether the United States Forest Service must publicly release the identities of agency personnel who responded to a wildfire that killed two Forest Service employees.

I

On July 20, 2003, the Forest Service engaged a wildfire in the Salmon-Challis National Forest in Idaho, which would later become known as the “Cramer Fire.” Two days later, Forest Service firefighters Shane Heath and Jeff Allen perished as they fought the blaze.

Four federal agencies investigated the incident: The Occupational Safety and Health Administration (“OSHA”), the…