In the case of Glen Scott Milner v. Department of the Navy, 2010, Milner filed a request under the Freedom of Information Act (FOIA) for data on explosive materials stored at a naval magazine in Washington state. The Navy refused to provide this information citing Exemption 2 of FOIA which allows agencies to withhold records related solely to internal personnel rules and practices. However, Milner argued that this exemption was being interpreted too broadly by government agencies and took his case all the way up to Supreme Court after losing in lower courts. The Supreme Court ruled in favor of Milner stating that Exemption 2 covers only records relating to issues like employee relations or human resources matters - not something as significant as public safety concerns regarding explosives storage. This ruling narrowed down what federal agencies can keep secret under FOIAs' Exemption 2 clause.

In the dissenting opinion for Glen Scott Milner v. Department of the Navy, Justice Alito argued that Exemption 2 in the Freedom of Information Act (FOIA) should be interpreted broadly to include all internal personnel rules and practices, not just those related to employee relations and human resources. He contended that this interpretation was consistent with prior court rulings and congressional intent when FOIA was enacted. Furthermore, he expressed concern about potential national security risks if sensitive information were released under a narrower interpretation of Exemption 2. In his view, it would be better for Congress rather than courts to decide whether such information should be disclosed.