The Freedom of Information Act (FOIA) allows citizens to access records generated by public institutions; for this reason, FOIA is of particular importance to journalists. Last week, The New York Times reported thatHillary Clinton “exclusively used a personal email account to conduct government business as secretary of state”, despite the law requiring her to use a government email for government business. Her exclusive reliance on a private email account made it impossible for journalists or anyone else to access any contents of her emails eligible for public acquisition under FOIA.