Milner v. Department of the Navy

Summary

The Court held that FOIA Exemption 2 protects only records related to employee relations and human resources, rejecting the broader 'High 2' interpretation that shielded internal rules risking circumvention of agency regulations. Justice Kagan delivered the opinion, reversing the Ninth Circuit. Justice Breyer dissented, arguing for stare decisis, and Justice Alito concurred, noting Exemption 7(F) alternatives.