CREW filed a Freedom of Information Act (FOIA) lawsuit in 2019 for internal DOJ documents that Barr had relied on in reaching the conclusion that the evidence supplied by the special counsel's office did not show that Trump had committed obstruction of justice. The department fought in court to prevent the release of the 2019 memo, arguing that it was protected under exceptions to FOIA for documents involving attorney-client privilege or that were used as part of a deliberative decision-making process. Jackson rejected those arguments earlier this month and ordered that the document be released in its entirety. In her May 3 decision, a fully unredacted version of which was released Tuesday, she said that the memo was formulated with the goal of providing advice on public relations strategy in response to the Mueller report, undercutting the government's position that it was privileged.