the courts under Article III." Because Nixon had asserted only a generalized need for confidentiality, the Court held that the more considerable public interest in obtaining the truth in the context of a criminal prosecution took precedence. Post-Watergate era Ford administration In the wake of Nixon's heavy use of executive privilege to block investigations of his actions, Ford was scrupulous in minimizing its usage. However, that complicated his efforts to keep congressional investigations under control. Political scientist Mark J. Rozell concludes that Ford's: failure to enunciate a formal executive privilege policy made it more difficult to explain his position to Congress. He concludes that Ford's actions were prudent; they likely salvaged executive privilege from the graveyard of eroded presidential entitlements because of his recognition that the Congress was likely to challenge any presidential use of that unpopular perquisite. Reagan administration In November 1982, President Ronald Reagan signed a directive regarding congressional requests for information. Reagan wrote that if Congress seeks information potentially subject to executive privilege, executive branch officials should "request the congressional body to hold its request in abeyance" until the president decides whether to invoke it. George H. W. Bush administration Before becoming attorney general in 1991, Deputy Attorney General William P. Barr issued guidance in 1989 about responding to congressional requests for confidential executive branch information. He wrote: "Only when the accommodation process fails to resolve a dispute, and a subpoena is issued does it become necessary for the president to consider asserting executive privilege". Clinton administration The Clinton administration invoked executive privilege on fourteen occasions. In 1998, President Bill Clinton became the first president since Nixon to assert executive privilege and lose in court when a federal judge ruled that Clinton aides could be called to testify in the Lewinsky scandal. Later, Clinton exercised a form of negotiated executive privilege when he agreed to testify before the grand jury called by Independent Counsel Kenneth Starr only after negotiating the terms under which he would appear. Declaring that "absolutely no one is above the law", Starr said such a privilege "must give way" and evidence "must be turned over" to prosecutors if it is relevant to an investigation. George W. Bush administration The Bush administration invoked executive privilege on six occasions. President George W. Bush first asserted executive privilege in December 2001 to deny disclosure of details regarding former attorney general Janet Reno, the scandal involving Federal