Cook v. Nat'l Archives & Records Admin., No. 13-1228 (2d Cir. 2014)Annotate this Case
Plaintiff filed suit under the Freedom of Information Act (FOIA), 5 U.S.C. 552, seeking disclosure of records held by NARA of archived presidential and vice-presidential materials submitted by or on behalf of former President George W. Bush and former Vice-President Richard B. Cheney. The court concluded that the records are protected by FOIA's Exemption 6, which permits the withholding of personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy. The records requested in this case were made for purposes of private speech, perhaps for preparation of memoirs, and reveal preliminary thinking and personal matters. Accordingly, the court affirmed the district court's grant of summary judgment to NARA.