"U.S. Immigration and Customs Enforcement must turn over an internal memo
that could reveal the agency's legal justification for mandating the
so-called Secure Communities deportation program, a federal judge ruled. ... To "adopt a legal position while shielding from public view the analysis
that yielded that position is offensive to FOIA," the 38-page ruling
states... ." Courthouse News Service, Oct. 26, 2011.