In United States Dept. of Justice v. Landano, 508 U.S. 165 (1993), a convicted murderer filed a Freedom of Information Act ("FOIA") request with the Federal Bureau of Investigation ("FBI"), seeking information to support a Brady claim (Brady v. Maryland). The FBI released several hundred pages of documents, but refused to release a number of other documents under the confidential informant exemption. Before the Court, the FBI asserted that all of its sources should be presumed confidential and that "the presumption could be overcome only with specific evidence that a particular source had no interest in confidentiality." Id. at 174. The Court held that the FBI was not entitled to a presumption of confidentiality. Citing legislative history, the Court reasoned that confidentiality does not depend on whether the agency typically regards the requested document as confidential, "but whether the particular source spoke with an understanding that the communication would remain confidential." Id. at 172. The Court, however, agreed with the FBI that certain circumstances may arise that will support an inference of confidentiality. See id. at 179. In so doing, the Court explained that there may well be other generic circumstances in which an implied assurance of confidentiality fairly can be inferred. . . . We agree that the character of the crime at issue may be relevant to determining whether a source cooperated with the agency with an implied assurance of confidentiality. So too may the source's relation to the crime. Id.