National Security Archive press release: “A District Court in the District of Columbia has ruled that an Executive Order [13,233] issued by President George W. Bush in 2001, which severely slowed or prevented the release of historic presidential papers is, in part, invalid. In a carefully constructed decision, the court held that the Archivist of the United States acts arbitrarily, capriciously, and contrary to law by relying on the Executive Order to delay release of the records of former presidents. The court did not reach the issue of whether it was permissible for President Bush to extend the authority over disclosure of presidential papers to a former president’s heirs or to former vice presidents.”