Last week, the law journal of the St. Mary’s University School of Law published an article entitled Foiled FOIA: The Excessive Exemption, which examines how courts have treated Exemption 3 in the wake of the OPEN FOIA Act of 2009. In sum, the author concludes that the 2009 amendment to Exemption 3 requiring specific reference to the Act was “needless” and should be repealed.