There is certainly an argument — especially in cases involving a sitting or former president — that very little can truly be considered “personal” given the public interest surrounding presidential conduct and decision-making. But legally speaking, the existing framework governing presidential and personal records may still provide Biden with at least some basis for trying to keep the recordings shielded from disclosure.
Of course, the bigger political question hanging over all of this is whether the audio recordings further expose concerns about Joe Biden’s mental sharpness during his time in office