Citizens for Responsibility & Ethics in Wash. v. U.S. Dep't of the Army (D.D.C.) -- ruling that communications between South Dakota state officials and the National Guard (a hybrid state-federal entity) did not fall within Exemption 5’s consultant corollary exception because they were not made for purpose of aiding the National Guard’s deliberations; noting that its ruling “produced an odd outcome considering that these discussions would be protected either under Exemption 5 (if wholly federal) and under South Dakota law (if wholly state) . . . and yet the very structure of the National Guard necessitates crossing federal-state lines.”

Summaries of all published opinions issued since April 2015 are available here.