The U.S.Supreme Court's 2011 ruling in Milner v.Department of the Navy gave

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The ruling in Milner v. Department of the Navy narrowed the scope of FOIA Exemption 2, which had previously been interpreted broadly to protect information relating to internal personnel rules and practices of an agency. The Court held that Exemption 2 only applies to information that is "related solely to the internal personnel rules and practices of an agency," and not to information that also has some connection to the agency's substantive functions.

The USSupreme Court's 2011 Ruling in Milner V