Milner v. Department of the Navy

The Navy (defendant) used Explosive Safety Quantity Distance (ESQD) data -- minimum spacing distances to prevent chain-reaction explosions -- to store explosives at its Puget Sound base, and Glen Milner (plaintiff) requested that data under FOIA; the Navy withheld it under Exemption 2, which protects material 'related solely to the internal personnel rules and practices of an agency,' relying on lower-court precedent extending that exemption to material whose disclosure could risk circumvention of the law. The district court granted the Navy summary judgment, and the Ninth Circuit affirmed on the ground the data told internal personnel how to do their jobs and its disclosure could risk circumvention of the law by bad actors; the Supreme Court granted certiorari.