Milner v. Department of the Navy Case Brief Summary | Law Case Explained

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Milner v. Department of the Navy, 562 U.S. 562 (2011)

In Milner versus Department of the Navy, we’ll see whether the Navy could refuse to release information about explosives stored on a Navy base after a citizen filed a Freedom of Information Act, or FOIA, request.

The Navy stores explosives at a base in Puget Sound, Washington, known as Naval Magazine Indian Island. The Navy uses data known as Explosive Safety Quantity Distance, or ESQD, to determine the minimum separation distances that explosive storage facilities must be constructed to avoid chain reaction explosions if one of the storage facilities accidentally detonates.

In 2003 and 4, Glen Milner, a Puget Sound resident, submitted FOIA requests for the ESQD data used on the Indian Island base. The Navy denied Milner’s request and refused to release the information, claiming that this data could threaten security at the base. When the Navy refused to release the data, it cited FOIA’s Exemption 2, which holds that agencies don’t have to disclose documents that are, quote, “related solely to the internal personnel rules and practices of an agency,” unquote. After the United States Court of Appeals for the District of Columbia Circuit’s holding in Crooker versus Bureau of Alcohol, Tobacco and Firearms, courts and agencies interpreted exemptions under Exemption 2 as either Low 2, which exempted human resource and employee relations materials, or High 2, which exempted records that, if disclosed, would risk circumventing the law.

Milner filed suit against the Navy to compel it to disclose the data. The district court granted summary judgment in favor of the Navy. Milner appealed. The court of appeals affirmed the district court’s holding and held that the ESQD data was predominantly used to instruct Navy personnel on how to do their jobs. Disclosing the data would risk circumventing the law by giving terrorists or other bad actors information about which storage unit would cause the most damage if it were hit. The court of appeals held that the data fell under the High Two exemption. The United States Supreme Court granted cert to resolve a circuit split on the meaning of Exemption Two.

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