A president has sole authority under PRA [Presidential Records Act]
to categorize records as personal or presidential during his/her presidency. Neither a court nor a jury is permitted to make or review such a categorization decision. Although there is no formal means in the PRA by which a president is to make that categorization, an outgoing president’s decision to excluded what he/she considers to be personal records from presidential records transmitted to the National Archives and Records Administration constitute a president’s categorization of those records under the PRA How can this case go further with this ruling?