Mealey's (March 29, 2023, 10:24 AM EDT) -- WASHINGTON, D.C. — The Second Circuit U.S. Court of Appeals correctly found that documents identifying Donald J. Trump’s pre-inauguration visitors do not constitute “agency records” and, as such, were not subject to disclosure in response to a journalist’s request under the Freedom of Information Act (FOIA), the U.S. Department of Homeland Security (DHS) tells the U.S. Supreme Court in a brief opposing the journalist’s petition for certiorari....