Supreme Court of the United States

Milner v. Department of Navy

March 7, 2011

Summary

The Supreme Court held that Exemption 2 of the Freedom of Information Act is limited to records concerning employee relations and human resources, rejecting the "High 2" doctrine that exempted internal records whose disclosure would risk circumvention of agency regulations. The Court reversed the Ninth Circuit's ruling upholding the Navy's withholding of explosives data under the broad exemption.