...In a 21-page decision, a three-judge panel on the U.S. Court of Appeals for the D.C. Circuit unanimously ruled that the memo was exempt from disclosure under the Freedom of Information Act (FOIA) on the basis of the presidential communications privilege... The Circuit Court upheld the lower court’s ruling, writing that “records of what was said by or directly to the President lie at the heart of the presidential communications privilege.” The Circuit Court also rejected Protect Democracy’s assertion that the court should make a “narrow exception” and require portions of the memo to be segregated and disclosed ...