National Security Archive v. CIA, No. 12-5201 (D.C. Cir. 2014)Annotate this Case
National filed suit under the Freedom of Information Act (FOIA), 5 U.S.C. 552 et seq., seeking the CIA's draft of Volume V concerning the Bay of Pigs invasion in the spring of 1961. The CIA claims that the draft of Volume V is exempt from disclosure under Exemption 5 of FOIA. The court affirmed the district court's grant of summary judgment to the CIA, applying the reasoning in Russell v. Department of the Air Force and Dudman Communications Corp. v. Department of the Air Force and concluding that in this case, which involves a draft agency history, the district court correctly concluded that the draft of Volume V is exempt in its entirety under Exemption 5.