Supreme Court of the United States
Milner v. Department of Navy
March 7, 2011179 L. Ed. 2d 268
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.
Holding
- Scope of FOIA Exemption 2. Exemption 2 encompasses only records relating to employee relations and human resources.
Docket 09-1163
Cited authorities
- 5 U.S.C. §1002
- 5 U.S.C. §552
- 5 U.S.C. §1002
- 5 U.S.C. §1002
- 100 Stat. 3207
- 5 U.S.C. §552
- 5 U.S.C. §1002
- 75 FR 711
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