Environmental Protection Agency v. Environmental Council of Sacramento, Inc.

How later courts describe this case

• denying discovery of names of participants in a medical study due to privacy interests of the individual participants
• stating, “it is well established that a district court must enforce a federal agency’s investigative subpoena if the information sought is ‘reasonably relevant’... and not ‘unduly burdensome’ to produce_
• “The word solely provides the key: the discrimination must result from the handicap and the handicap alone.”
• “[i]n general, we do not address issues not briefed”
• infant with birth defects denied surgery was not otherwise qualified