Congress and no judicial precedent" immunized the contractors from tort liability, the Federal Tort Claims Act specifically excludes contractors, and tort liability would not interfere with government operations. First Amendment According to Goldstein, Garland has "tended to take a broader view" of First Amendment rights. In cases involving the Freedom of Information Act and similar provisions related to government transparency, "Judge Garland's rulings reflect a preference for open government." In ACLU v. CIA (2013), Garland wrote for a panel unanimously rejecting the agency's Glomar response and ordering it to process the ACLU's FOIA request regarding targeted killings by CIA drones. In Cause of Action v. FTC (2015), Garland wrote for a panel unanimously overturning the agency's limitation on FOIA fee waivers to large news outlets. In Lee v. Department of Justice (2005), Garland dissented from the denial of rehearing en banc after the D.C. Circuit affirmed the district court's order holding reporters in contempt of court for refusing to testify about their anonymous sources during the Wen Ho Lee investigation. Garland wrote that the panel had erred in failing to "weigh the public interest in protecting the reporter's sources against the private interest in compelling disclosure" and that the decision "undermined the Founders' intention to protect the press 'so that it could bare the secrets of government and inform the people.'" In Initiative & Referendum Institute v. U.S. Postal Service (2005), Garland wrote for the court, holding that a U.S. Postal Service regulation banning signature-gathering for petitions at post offices violated the First Amendment. Garland found the regulation to be facially overbroad and not narrowly tailored. In cases involving campaign finance reform laws, Garland has applied Citizens United v. Federal Election Commission when he believed that he was compelled to do so, but he has not sought to extend its holding. In Wagner v. Federal Election Commission (2015), Garland wrote for the unanimous en banc D.C. Circuit in upholding a prohibition on campaign contributions from federal contractors because of the governmental interest in preventing corruption. In National Association of Manufacturers v. Taylor (2009), Garland wrote for the court in a decision upholding the constitutionality of lobbyist disclosure requirements under the Honest Leadership and Open Government Act. Professor Rick Hasen, an election-law expert, writes that Garland's opinions on election law are characterized by careful application of precedent and indicate that Garland believes in reasonable regulation. Garland has addressed a number of