Perhaps the underlying transparency project that Cross, Emerson, and current advocates have undertaken misunderstands the state and its potential for being opened. … FOIA might only have limited utility as a means to achieve an effective or accessible state, and as such it might work best if recognized as an administrative, essentially bureaucratic apparatus rather than as a provider of transcendent, constitutional-ish rights.

David E Pozen; Michael Schudson, Troubling Transparency- The…, loc. 304