NY Times v CIA, the court disagreed that the president does not have to follow.
The Times next contends that the President’s tweet and statements to the Wall Street Journal interviewer declassified the fact that the program existed, thus precluding the CIA from invoking FOIA Exemptions 1 and 3. The Times argues that this “conclusion flows inexorably from the President’s supreme authority in matters of classification.” This novel argument is without merit. It is true that the President has broad authority to classify and declassify, derived from the President’s dual role “as head of the Executive Branch and as Commander in Chief” of the armed forces.74 The “authority to classify and control access to information bearing on national security . . . flows primarily from this constitutional investment of power in the President and exists quite apart from any 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 explicit congressional grant.”75 To make its declassification claim, the Times essentially recasts its “official acknowledgement” claim as one of “inferred declassification.” To prevail in any claim of declassification, inferred or otherwise, the Times’s must show: first, that President Trump’s statements are sufficiently specific; and second, that such statements subsequently triggered actual declassification. The first is easily disposed of because we have already found that the statements are insufficiently specific to quell any “lingering doubts” about what they reference. The second requires further discussion. Declassification cannot occur unless designated officials follow specified procedures.76
Bolding is mine. A president has to be specific about what he declassified. He can't just say "all things I want declassified to avoid me being in trouble are declassified".
The courts also ruled this way in Leopold v Dept of Justice,
https://law.justia.com/cases/federa...ct-of-columbia/dcdce/1:2019cv01278/206853/86/