The Supreme Court decided today not to accept New Hampshire Right to Life v. Department of Health and Human Services, a case in which the Court of Appeals for the First Circuit found that Planned Parenthood's "Manual of Medical Standards and Guidelines" was protected from disclosure under Exemption 4.  Justice Thomas issued a dissent joined by Justice Scalia, stating that the First Circuit's decision warranted review because it "perpetuates an unsupported interpretation of an important federal statute and further muddies an already amorphous test."