Department of the Interior and Bureau of Indian Affairs v. Klamath Water Users Protective Association

Interior and its Bureau of Indian Affairs (defendants) consulted with tribes advocating their own interests in allocating scarce Klamath River water rights against competing non-tribal users; a competing water users' association (plaintiff) sought disclosure under FOIA of documents from those consultations, most prepared by the tribes themselves, but the agencies withheld them as intra-agency Exemption 5 material, and the district court granted the agencies summary judgment before the Ninth Circuit reversed.