8
Opinion of the Court
limited exemptions do not obscure the basic policy that disclosure, not secrecy, is the dominant objective of the Act," Department of Air Force v. Rose, 425 U. S. 352, 361 (1976); "[c]onsistent with the Act's goal of broad disclosure, these exemptions have been consistently given a narrow compass," Department of Justice v. Tax Analysts, 492 U. S. 136, 151 (1989); see also FBI v. Abramson, 456 U. S. 615, 630 (1982) ("FOIA exemptions are to be narrowly construed").
A
Exemption 5 protects from disclosure "inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with the agency." 5 U. S. C. § 552(b)(5). To qualify, a document must thus satisfy two conditions: its source must be a Government agency, and it must fall within the ambit of a privilege against discovery under judicial standards that would govern litigation against the agency that holds it.
Our prior cases on Exemption 5 have addressed the second condition, incorporating civil discovery privileges. See, e. g., United States v. Weber Aircraft Corp., 465 U. S. 792, 799-800 (1984); NLRB v. Sears, Roebuck & Co., 421 U. S. 132, 148 (1975) ("Exemption 5 withholds from a member of the public documents which a private party could not discover in litigation with the agency"). So far as they might matter here, those privileges include the privilege for attorney work-product and what is sometimes called the "deliberative process" privilege. Work product protects "mental processes of the attorney," United States v. Nobles, 422 U. S. 225, 238 (1975), while deliberative process covers "documents reflecting advisory opinions, recommendations and deliberations comprising part of a process by which governmental decisions and policies are formulated," Sears, Roebuck & Co., 421 U. S., at 150 (internal quotation marks omitted). The deliberative process privilege rests on the obvious realization that officials will not communicate candidly among them-
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