Judges don't just issue rulings out of thin air. They issue rulings in legal proceedings. You have to read almost all the way down to the end of the article to find out who was actually petitioning a court to release them. It turns out it was a group of media outlets that filed a Freedom of Information Act (FOIA) request for them, and the judge simply ruled that public disclosure under a FOIA request doesn't outweigh the need for confidentiality in an ongoing investigation at this time.
True, Judicial Watch was one who requested the notes. The judge made the decision based on ‘law enforcement proceedings. Sounds more official than ‘an investigation’. My question is - will there be a law enforcement proceeding’ or just discussion?
“The FBI quickly declined to release all nine memos, stating on June 16, “The records responsive to your request are law enforcement records. There is a pending or prospective law enforcement proceeding relevant to these responsive records, and the release of the information could reasonably be expected to interfere with enforcement proceedings.”