The ruling reverses a lower court that had ordered the paper's release.
The three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit ruled Friday that the release of the document could limit the flexibility of U.S. negotiators.
The paper had been prepared during negotiations for a Free Trade Agreement of the Americas, conducted in the 1990s and 2000s, which never resulted in a deal.
The appeals court's ruling opens with a 1796 statement by President George Washington, refusing a request from the U.S. House for a copy of instructions provided to the U.S. minister who negotiated a treaty with the king of Great Britain.
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