Court Cases
276 Illinois appellate & Supreme Court cases that substantively address FOIA or OMA, 1973–present. Kept separate from the PAC opinions/letters corpus (different schema and provenance) —browse opinions & letters separately.
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276 of 276 cases
- Balzer v. Northeast Illinois Regional Commuter Railroad CorporationFOIAReversed and remandedFOIA Response Process
The court held that a FOIA request is considered 'received' when it arrives at the public body's server, regardless of whether a third-party security filter holds the email in a queue. Because Metra…
- Carl Lenard and Prisoner Media-X v. The Office of the Illinois Secretary of StateFOIARule 23AffirmedFOIA Response Process
The court affirmed the dismissal of the plaintiff's complaint because he failed to comply with statutory requirements for submitting FOIA requests. Consequently, the defendant never received the…
- Cleother Tidwell v. City of AltonFOIARule 23AffirmedSearch & Production
Tidwell submitted a FOIA request to the City of Alton for the court docket in a lawsuit naming the City as a defendant. The City denied the request because it did not possess the court file and…
- Cleother Tidwell v. Illinois Department of CorrectionsFOIARule 23AffirmedGeneral Records Exemptions
Inmate Cleother Tidwell requested the names and staffing roster of medical personnel at Pinckneyville Correctional Center under FOIA. IDOC denied the request under Section 7(1)(e-6), which exempts…
- Dorman v. The Madison County Board, et al.FOIAReversed in partFees & Burdensome Requests
The appellate court reversed the circuit court's dismissal of a FOIA complaint, holding that the public bodies failed to demonstrate compliance with the statutory requirements of 5 ILCS 140/3(g)…
- Edgar D. Pal v. Office of the Public Access CounselorOMARule 23AffirmedOther
Plaintiff filed two OMA requests for review with the PAC alleging the Chicago Park District Board violated the Open Meetings Act, which the PAC did not decide for over two years despite a 60-day…
- Lucy Parsons Labs v. The Chicago Police DepartmentFOIAReversed in partFOIA Response Process
The appellate court reversed the circuit court's denial of civil penalties under FOIA, finding that the Chicago Police Department's justifications for its significant delay in responding to the…
- Mark Donham and Craig Rhodes v. Illinois Department of Natural ResourcesFOIARule 23AffirmedFOIA Response Process
Plaintiffs challenged management of Cypress Creek Hill Nature Preserve and alleged FOIA violations for untimely responses, withheld communications, and redaction of threatened and endangered species…
- Marshall King v. The Livingston County Sheriff's OfficeFOIARule 23AffirmedSearch & Production
Inmate Marshall King requested racial profiling records for an officer from the Livingston County Sheriff's Office, which responded the records had to be sought from Pontiac Police. The trial court…
- NBC Subsidiary (WMAQ-TV) LLC v. Chicago Police DepartmentFOIARule 23ReversedFOIA Response Process
The circuit court's decision to deny plaintiff's request for civil penalties under section 11(j) of the Freedom of Information Act is reversed and the cause is remanded. The court's finding that…
- People v. Rucker (Better Government Association et al., Intervenors)Rule 23ReversedPolice & Investigative Records
This is a criminal case where the court addressed the improper application of civil discovery rules to restrict public access to records. The court reversed the trial court's protective order, noting…
- Tobias v. City of Chicago Office of the MayorFOIARule 23Reversed in partSearch & Production
The court affirmed the trial court's finding that the City's search for records was reasonable and adequate. However, it reversed the grant of summary judgment regarding statutory civil penalties,…
- Bobby R. Turner, Jr. v. Amy VedraFOIARule 23AffirmedFOIA Response Process
The circuit court properly granted the respondent's motion to dismiss because no records existed responsive to the petitioner's FOIA request. Furthermore, the court held that a self-represented…
- Bradley Walters v. McHenry County Sheriff’s OfficeFOIARule 23AffirmedFees & Burdensome Requests
The court held that the plaintiff's FOIA appeal was not moot because he sought civil penalties and had not received the records from the defendant. On the merits, the court affirmed the dismissal,…
- Charles Graham v. Chicago Police DepartmentFOIARule 23RemandedFOIA Response Process
The appellate court vacated the circuit court's dismissal of the defendant's FOIA-based complaint for declaratory and injunctive relief. The court held that the circuit court should have transferred…
- Disgrase Felyer v. The Village of Arlington HeightsFOIARule 23AffirmedFOIA Response Process
The appellate court affirmed the circuit court's grant of summary judgment in favor of the Village of Arlington Heights in a FOIA dispute. The court held that the municipality complied with both…
- Jared M. Staake v. The Sangamon County Sheriff’s OfficeFOIARule 23AffirmedPolice & Investigative Records
The appellate court affirmed the dismissal of the plaintiff's FOIA complaints, holding that he failed to establish how the requested recordings were relevant to his claims under section 7(1)(e-10).…
- Joel W. Tynis v. The McHenry County Sheriff’s DepartmentFOIARule 23AffirmedGeneral Records Exemptions
The court affirmed the dismissal of the plaintiff's FOIA complaint, holding that the Sheriff's redactions for personal information and investigative plans were consistent with FOIA exemptions. The…
- NBC Subsidiary (WMAQ-TV) LLC v. Chicago Police DepartmentFOIAAffirmedPolice & Investigative Records
The court affirmed the denial of a FOIA request for body camera footage, holding that the recordings were exempt from disclosure because the subjects had a reasonable expectation of privacy. The…
- Taylor v. Cook County State’s Attorney’s OfficeFOIAReversed in partFOIA Response Process
The court held that the State's Attorney's Office failed to meet its burden of proof under FOIA by relying on conclusory affidavits to justify withholding records. The case was remanded with…
- Zillow, Inc. v. Moultrie County and Moultrie County Assessment OfficeFOIARule 23DismissedFOIA Response Process
The appellate court dismissed the appeal for lack of jurisdiction, holding that the trial court abused its discretion in finding no just reason to delay the appeal under Illinois Supreme Court Rule…
- Better Government Ass’n v. City Colleges of ChicagoFOIAReversed in partPersonnel & Student Records
The court held that records requested under FOIA that are subject to FERPA protections must be produced only after the circuit court conducts an in camera inspection to redact personally identifiable…
- Eberhardt v. Village of Tinley ParkOMAAffirmedMeeting Conduct & Participation
The court addressed whether a violation of the Open Meetings Act could render a municipal contract void ab initio. The court held that subsequent ratification of the board's actions in properly…
- Jamal Shehadeh v. The City of TaylorvilleFOIARule 23AffirmedPublic Records Definition
The court affirmed the dismissal of a FOIA complaint, holding that a letter sent by the plaintiff to the mayor did not constitute a 'public record' because it did not pertain to public business and…
- Jason F. Woolsey v. The Illinois State PoliceFOIARule 23ReversedGeneral Records Exemptions
The appellate court reversed the trial court's order, holding that section 7.5(v) of the Illinois Freedom of Information Act prohibits the Illinois State Police from disclosing Firearm Owners…
- McBroom v. Logan County Sheriff’s OfficeFOIARule 23AffirmedPublic Records Definition
The trial court properly dismissed the plaintiff's FOIA complaint because most of the requested information did not constitute a public record, and the defendant's uncontroverted affidavit…
- Nathanael Harsy v. Perry County Sheriff’s OfficeFOIARule 23AffirmedFOIA Response Process
The court affirmed the dismissal of the plaintiff's FOIA complaint as moot because the defendant supplemented its responses, provided explanations for withheld records, and refunded overcharges. The…
- Robin W. Hickman v. Dora J. MannFOIARule 23AffirmedSearch & Production
The court affirmed the dismissal of a FOIA complaint where uncontradicted evidence showed no responsive documents existed. The court also held that naming the compliance officer instead of the…
- Darron Brewer v. City of Chicago, et al.FOIARule 23Reversed in partFOIA Response Process
The appellate court reversed the circuit court's grant of summary judgment, finding the record insufficient to establish by clear and convincing evidence that a FOIA exemption justified the City's…
- Edgar County Watchdogs v. Joliet TownshipFOIAAffirmedFees & Burdensome Requests
The court held that a public body does not act in bad faith under FOIA by requesting reimbursement for third-party costs incurred to fulfill a request for a hard drive image when the public body…
- Glynn v. Department of CorrectionsFOIAReversed and remandedGeneral Records Exemptions
The appellate court reversed the circuit court's grant of summary judgment to the Department of Corrections regarding a FOIA request for security video footage. The court held that the circuit court…
- Jamal Shehadeh v. Sangamon County SheriffFOIARule 23AffirmedFOIA Response Process
The appellate court affirmed summary judgment for the Sheriff, holding that the plaintiff failed to provide sufficient information in his FOIA request to trigger the exception to the section…
- Kenneally v. Department of CorrectionsFOIAAffirmedGeneral Records Exemptions
The court held that the specific disclosure requirements under section 3-5-1(b) of the Unified Code of Corrections control over the general disclosure provisions of FOIA. Because the Department of…
- Kieken v. City of JolietFOIAAffirmedFees & Burdensome Requests
The court affirmed an award of attorney fees to a FOIA requester, holding that the plaintiff was a prevailing party entitled to fees even though the City produced the requested documents after the…
- Makiel v. FoxxFOIARule 23Reversed and remandedPolice & Investigative Records
The trial court erred in granting the defendant's motion for summary judgment because the defendant failed to demonstrate that the requested records were exempt from disclosure under section…
- Michael Lambert v. City of Chicago, Chicago Fire Department, and Chicago Police DepartmentFOIARule 23DismissedFOIA Response Process
The appellate court dismissed the appeal for lack of jurisdiction. The court held that the plaintiff failed to timely file his notice of appeal following the trial court's ruling on his FOIA-based…
- Thomas v. County of CookFOIAAffirmedGeneral Records Exemptions
The court affirmed the denial of a FOIA request for autopsy photographs, holding that such records are exempt from disclosure under section 7(1)(c) of FOIA because their release would constitute an…
- Annette Elmore v. City of Chicago, Board of EducationFOIARule 23AffirmedSearch & Production
The court affirmed the summary judgment in favor of the defendant, finding that the Board of Education conducted an adequate search and disclosed all responsive documents in its possession. The court…
- Ballew v. Chicago Police DepartmentFOIAAffirmedPolice & Investigative Records
The court affirmed the trial court's judgment, holding that the Chicago Police Department met its burden of proving by clear and convincing evidence that the requested records were exempt from…
- Calloway v. Chicago Police DepartmentFOIAReversed in partFOIA Response Process
The court held that the circuit court lacked a sufficient basis to grant summary judgment regarding FOIA requests for records involving a minor because the defendant's affidavit was inadequate and no…
- Chapman v. Chicago Department of FinanceFOIAReversedGeneral Records Exemptions
The Supreme Court held that the records requested by the plaintiff constituted 'file layouts' within the meaning of section 7(1)(o) of FOIA. Consequently, the court ruled the records were exempt from…
- Chicago Sun-Times v. Chicago Police DepartmentFOIARule 23Reversed and remandedSearch & Production
The circuit court erred in granting summary judgment to the plaintiff without conducting an in camera review of the requested records. The appellate court remanded the case with instructions for the…
- Darrion O. Foote v. Winnebago County Sheriff’s OfficeFOIARule 23AffirmedFOIA Response Process
The appellate court affirmed the trial court’s dismissal of the plaintiff's complaint for failure to state a claim. The court held that the plaintiff failed to plead a cause of action because the…
- Donley v. City of SpringfieldFOIAReversedFees & Burdensome Requests
The court held that a FOIA requester who failed to provide necessary information to the public body to facilitate the disclosure of records is not entitled to attorney fees. The court concluded that…
- Edgar Pal v. City of Elmhurst and Elmhurst City CouncilFOIA + OMARule 23AffirmedFOIA Response Process
The Appellate Court affirmed the dismissal of the plaintiff’s complaint alleging violations of the Open Meetings Act and FOIA, finding the record insufficient for appellate review. The defendants'…
- Hart v. Illinois State PoliceFOIAAffirmedGeneral Records Exemptions
The court held that the Illinois State Police could not withhold FOID card application and denial letters under FOIA exemptions. The court determined that section 7.5(v) does not apply to requests…
- Hurlbert v. EdmondsFOIAAffirmedGeneral Records Exemptions
The court affirmed the denial of a FOIA request for GIS data, holding that the county properly invoked the section 7(1)(i) exemption for valuable commercial information. The court further held that…
- Jason E. Cohee v. Peoria County State’s Attorney’s OfficeFOIARule 23AffirmedGeneral Records Exemptions
The appellate court affirmed the trial court's dismissal of the plaintiff's FOIA complaint, holding that the court did not err in denying a motion to continue or in finding that the requested…
- John Kraft and Edgar County Watchdogs, Inc. v. City of KankakeeFOIARule 23AffirmedFOIA Response Process
The appellate court affirmed the dismissal of the plaintiffs' FOIA complaint, finding the matter moot because the plaintiffs eventually received the requested documents. The court further held that…
- Kraft v. Chicago Police DepartmentFOIARule 23AffirmedFees & Burdensome Requests
The appellate court affirmed the circuit court's grant of summary judgment in favor of the Chicago Police Department. The court held that the department sufficiently established that the plaintiffs'…
- Martinez v. City of SpringfieldFOIAReversed in partFees & Burdensome Requests
The court held that a FOIA requester who receives requested documents after filing suit may still be considered a prevailing party entitled to attorney fees. The appellate court reversed the trial…
- Nathson Fields v. Cook County State’s Attorney’s OfficeFOIARule 23RemandedGeneral Records Exemptions
The appellate court vacated the trial court's grant of summary judgment in favor of the State's Attorney's Office regarding a FOIA request for witness relocation records. The case was remanded with…
- Nolan Watson v. Illinois Department of CorrectionsFOIARule 23AffirmedFees & Burdensome Requests
The appellate court affirmed the circuit court's denial of attorney fees and costs under section 11(i) of FOIA. The court held that because the plaintiff did not prevail on the merits of his FOIA…
- River Breeze, LLC v. GranholmFOIARemandedPublic Body Definition
The court held that the trial court erred in dismissing the plaintiff's FOIA claim at the pleading stage by prematurely determining that Aurora Downtown was not a 'subsidiary body' subject to FOIA.…
- Robinson v. Township High School District 113FOIARule 23AffirmedFOIA Response Process
The appellate court affirmed the trial court's denial of FOIA disclosure because the plaintiff failed to include the in camera emails in the record on appeal. Consequently, the court presumed the…
- Shane A. Lyberger v. Troy D. CannonFOIARule 23AffirmedSearch & Production
The appellate court affirmed the dismissal of the plaintiff's FOIA complaint, finding the request moot because the defendant had provided all responsive records in his possession. The court held that…
- Staake v. Department of CorrectionsFOIAReversed in partFOIA Response Process
The court held that while mid-litigation disclosure of FOIA records does not automatically establish bad faith, the Department of Corrections' failure to provide a detailed factual basis for its…
- Trent Jacob Warren v. The Department of CorrectionsFOIARule 23AffirmedFees & Burdensome Requests
The appellate court affirmed the dismissal of the plaintiff's FOIA complaint, holding that the Department of Corrections properly denied the requests as unduly burdensome under section 3(g) because…
- Trent Warren v. The City of UrbanaFOIARule 23AffirmedGeneral Records Exemptions
The appellate court affirmed the dismissal of the plaintiff's FOIA complaint, holding that the municipality properly redacted information under FOIA exemptions 7(1)(b) and 7(1)(c). The court further…
- Chicago Sun-Times v. Chicago Transit AuthorityFOIAReversed in partGeneral Records Exemptions
The court held that summary judgment was inappropriate because genuine issues of material fact existed regarding whether the release of surveillance video would jeopardize the effectiveness of the…
- Chicago Sun-Times v. Cook County Health and Hospitals SystemFOIAReversedSearch & Production
The Supreme Court held that the Cook County Health and Hospitals System was not required under FOIA to create a new record by extracting and compiling data from its existing database to fulfill the…
- City of Bloomington v. RaoulOMAReversedClosed Sessions
The court held that the Bloomington City Council violated the Open Meetings Act by discussing topics outside the scope of the litigation exception during a closed session. The court determined that…
- Fisher v. Office of the Illinois Attorney GeneralFOIAAffirmedGeneral Records Exemptions
The court affirmed the denial of a FOIA request, holding that communications between the Attorney General's office and a third-party claims administrator regarding a settlement distribution plan…
- Green v. Chicago Police DepartmentFOIAReversedPolice & Investigative Records
The court addressed whether the Chicago Police Department was required to produce closed complaint register files under FOIA. The appellate court reversed the circuit court's judgment, ruling against…
- Greer v. Board of Education of the City of ChicagoFOIAReversed in partFees & Burdensome Requests
The court affirmed the denial of a default judgment against the Board but reversed the grant of summary judgment, finding that the Board's affidavit failed to establish that the plaintiff's FOIA…
- Lucy Parsons Labs v. City of Chicago Mayor’s OfficeFOIAReversed in partFOIA Response Process
The court reversed a summary judgment in favor of the City, holding that the City failed to demonstrate that the requested 'action plan' was entirely exempt under FOIA. The case was remanded for the…
- Marlon L. Watford v. James Rowe, Jamie Boyd, Nancy Nicholson, and Bobbi WheelerFOIARule 23DismissedFOIA Response Process
The court affirmed the dismissal of the plaintiff's FOIA complaint because the requested discovery materials were already subject to a discovery order in the plaintiff's separate postconviction…
- Rodney Love v. City of Chicago and Ralph PriceFOIARule 23AffirmedFOIA Response Process
The appellate court affirmed the trial court's grant of summary judgment in favor of the defendants. The court held that the plaintiff failed to present claims of error supported by well-reasoned…
- Rodney Love v. Illinois State PoliceFOIARule 23AffirmedFOIA Response Process
The appellate court affirmed the dismissal of the plaintiff's FOIA complaint. The court held that due to numerous deficiencies in the plaintiff's brief and the failure to provide a complete record of…
- Shehadeh v. RaoulFOIARule 23AffirmedFOIA Response Process
The appellate court affirmed the dismissal of the plaintiff's mandamus complaint, finding that he failed to state a claim upon which relief could be granted. The court noted that the plaintiff sought…
- Vernon Tolbert v. Chicago Police DepartmentFOIARule 23AffirmedPolice & Investigative Records
The court held that the doctrine of res judicata bars the plaintiff from raising a FOIA claim that relies on materials previously litigated between the same parties concerning the same underlying…
- Watson v. FoxxFOIARule 23AffirmedFees & Burdensome Requests
The appellate court affirmed the dismissal of the plaintiff's complaint for FOIA costs and civil penalties. The court held that the plaintiff failed to demonstrate entitlement to attorney fees or…
- Williams v. BruscatoFOIAAffirmedFOIA Response Process
The court affirmed the denial of statutory penalties under FOIA section 11(j), finding that the defendant did not act in bad faith in responding to the plaintiff's records request. The court further…
- Antonio Sherrod v. The City of KankakeeFOIARule 23AffirmedSearch & Production
The appellate court affirmed the dismissal of the plaintiff's FOIA complaint, finding that the claims were moot because the City had produced the requested records. The court further held that the…
- Jamal Shehadeh v. Sheriff Michael DowneyFOIARule 23AffirmedGeneral Records Exemptions
The appellate court affirmed the dismissal of the plaintiff's FOIA complaint, holding that the requested information was either not a public record or was exempt from disclosure under section 7 of…
- King v. Cook County Health & Hospitals SystemFOIAReversed in partGeneral Records Exemptions
The court held that zip codes derived from mental health records are protected from disclosure under FOIA by the Mental Health and Developmental Disabilities Confidentiality Act. The appellate court…
- Mancini Law Group, P.C. v. Schaumburg Police DepartmentFOIARule 23AffirmedGeneral Records Exemptions
The Supreme Court held that the Schaumburg Police Department properly redacted personal information from traffic accident reports under FOIA. The court determined that the privacy interests protected…
- Mohammad v. Chicago Police DepartmentFOIARule 23AffirmedSearch & Production
The appellate court affirmed the circuit court's grant of summary judgment in favor of the Chicago Police Department. The court held that the plaintiff failed to demonstrate a genuine issue of…
- Nolan Watson v. Lisa WeitekampFOIARule 23AffirmedPublic Body Definition
The appellate court affirmed the dismissal of the plaintiff's complaint because he failed to state a cause of action under FOIA. The court held that a FOIA claim must be brought against a public…
- People v. VelazquezFOIARemandedFOIA Response Process
The court held that the circuit court erred in dismissing a FOIA-based motion for injunctive or declaratory relief on the grounds that it was filed in the wrong division. The appellate court ruled…
- Samuel Gayden v. Illinois Department of CorrectionsFOIARule 23AffirmedGeneral Records Exemptions
The appellate court affirmed the dismissal of the plaintiff's FOIA complaint, holding that specific provisions of the Corrections Code and Administrative Code regarding inmate access to records…
- Scott D. Peery v. Madison County State's Attorney's OfficeFOIARule 23Reversed in partFOIA Response Process
The court held that the circuit court improperly imposed a civil penalty against the public body because the evidence did not demonstrate a willful or intentional failure to comply with FOIA. The…
- Scott Peters v. Katherine M. Keefe, et al.FOIARule 23AffirmedFOIA Response Process
The plaintiff, an inmate, filed suit alleging violations of FOIA and constitutional rights regarding the denial of his information requests. The appellate court affirmed the trial court's dismissal…
- Vincent Boggan v. FOIA Office of the Department of CorrectionsFOIARule 23AffirmedFOIA Response Process
The circuit court's denial of the petitioner's request for civil penalties under FOIA was not against the manifest weight of the evidence. The appellate court found no evidence that the Department…
- Vincent Carter v. John BaldwinFOIARule 23AffirmedFOIA Response Process
The court affirmed the denial of civil penalties under FOIA, finding that the Department of Corrections did not willfully or intentionally violate the Act. The record demonstrated that the Department…
- Barner v. FairburnFOIAAffirmedFOIA Response Process
The appellate court affirmed the dismissal of the plaintiff's FOIA complaint, finding that the defendants' documentation refuted the plaintiff's claims. The court also held that the trial court did…
- City of Chicago v. Fraternal Order of Police, Chicago Lodge No. 7FOIAAffirmedPolice & Investigative Records
The court held that an arbitration award requiring the destruction of police misconduct records violated a well-defined public policy favoring the retention of public records. The court reasoned that…
- Fraternal Order of Police, Chicago Lodge No. 7 v. City of ChicagoFOIARule 23DismissedPolice & Investigative Records
The court dismissed the appeal as moot because the underlying Chicago Police Department complaint registry files sought by the FOIA requester had already been released. The court declined to address…
- Hosey v. City of JolietFOIAAffirmedPolice & Investigative Records
The court affirmed the denial of a FOIA request for videotaped police interviews, holding that section 103-2.1(g) of the Code of Criminal Procedure prohibits the disclosure of such records. The court…
- Joseph Varan v. Jesse White, in His Official Capacity as Illinois Secretary of StateFOIARule 23Reversed and remandedFees & Burdensome Requests
The appellate court held that the circuit court erred in granting summary judgment to the defendant regarding the imposition of copying fees. Because the defendant failed to timely respond to the…
- Kelly v. Village of KenilworthFOIAReversed in partFOIA Response Process
The court held that while the defendants demonstrated an ongoing investigation under FOIA section 7(1)(d), they failed to meet their burden of proving that the entirety of the withheld files were…
- Metropolitan Alliance of Police v. City of Crystal LakeFOIARule 23DismissedRequester Status
The appellate court dismissed the appeal as moot where the parties had settled the underlying dispute before the notice of appeal was filed. The court further held that no exceptions to the mootness…
- NBC Subsidiary (WMAQ-TV) LLC v. Chicago Police DepartmentFOIAAffirmedPolice & Investigative Records
The court held that records concerning the police shooting of a minor are not exempt from FOIA disclosure under the Juvenile Court Act's confidentiality provisions. The court determined that the…
- Raymond Serio v. Putnam County Sheriff's DepartmentFOIARule 23AffirmedRequester Status
The appellate court affirmed summary judgment for the defendant, finding that the plaintiff, an inmate, failed to comply with the procedural requirements of FOIA section 7(1)(e-10). The plaintiff did…
- Rushton v. Department of CorrectionsFOIAAffirmedPublic Records Definition
The Supreme Court held that a settlement agreement between a private medical contractor and the estate of a deceased inmate is a public record subject to FOIA disclosure when the contractor performs…
- Sweeney v. Algonquin Township Road DistrictFOIARule 23AffirmedFOIA Response Process
The appellate court affirmed the circuit court's judgment in favor of the plaintiffs regarding their FOIA complaint and the dismissal of the defendant's counterclaims. The court also held that the…
- Timpone v. Illinois Student Assistance Comm’nFOIAReversedGeneral Records Exemptions
The court held that the names of Monetary Award Program (MAP) grant recipients are exempt from disclosure under FOIA section 7(1)(b) because their release would constitute a clearly unwarranted…
- Turner v. Joliet Police DepartmentFOIAAffirmedFOIA Response Process
The court affirmed the dismissal of the plaintiff's FOIA complaint, finding that the defendant properly applied exemptions and that the claims became moot once the requested documents were released.…
- Walker v. BruscatoFOIAAffirmedGeneral Records Exemptions
The court affirmed summary judgment for the State's Attorney, holding that the plaintiff's FOIA request for grand jury materials was properly denied because the requested records were exempt from…
- Williams v. BruscatoFOIAReversed in partGeneral Records Exemptions
The court addressed whether grand jury records are exempt from FOIA disclosure under the exemption for information prohibited from disclosure by federal or state law. The court held that while…
- Blackman v. City of ChicagoFOIARule 23AffirmedSearch & Production
The appellate court affirmed the circuit court's grant of summary judgment in favor of the City of Chicago, finding that the City conducted a reasonable search for requested police records in good…
- Blanco v. Joliet Police DepartmentFOIARule 23AffirmedFOIA Response Process
The appellate court affirmed the circuit court's dismissal of the plaintiff's FOIA complaint due to an inadequate record on appeal. Because the plaintiff failed to provide necessary transcripts or…
- Bocock v. Will County SheriffFOIAReversed in partFees & Burdensome Requests
The court affirmed the dismissal of two FOIA complaints but reversed the dismissal of a third, finding that the plaintiff's request was not fatally unclear. The court held that the public body failed…
- Charles Bocock v. Will County SheriffFOIARule 23Reversed in partSearch & Production
The court held that a FOIA request for a milk container was moot due to lack of possession. It affirmed the denial of civil penalties and document requests due to an inadequate record, but reversed…
- Charles Bocock v. Will County SheriffFOIARule 23Reversed in partFOIA Response Process
The court affirmed the dismissal of complaints regarding equal protection and requests for barber and meal schedules. However, it reversed the dismissal of the complaint regarding a FOIA request for…
- Chicago Tribune Co. v. Cook County Assessor’s OfficeFOIAAffirmedGeneral Records Exemptions
The court affirmed the trial court's ruling that the Cook County Assessor’s Office failed to justify withholding property valuation records under the FOIA deliberative process exemption. The…
- City of Danville v. MadiganFOIAAffirmedPublic Records Definition
The court held that documents possessed by a public body are subject to FOIA disclosure if they pertain to public business, provided they do not fall under specific statutory exemptions. The court…
- City of Danville v. Madigan and FlynnFOIARule 23AffirmedPublic Records Definition
The court held that the Attorney General's binding opinion requiring the City of Danville to disclose records under FOIA was not clearly erroneous. The court clarified that while not all documents in…
- City of East Peoria v. Property Tax Appeal BoardOMARule 23RemandedMeeting Conduct & Participation
The court vacated the Property Tax Appeal Board's decision because the intervenor was improperly denied a hearing. The court held that the agency's Open Meetings Act violations were remedied by the…
- Garlick v. Bloomingdale TownshipFOIAAffirmedSearch & Production
The court affirmed the dismissal of a FOIA complaint seeking property assessment data in a specific electronic format, finding the claim moot and barred by collateral estoppel. The court also…
- Hites v. Waubonsee Community CollegeFOIAReversed and remandedFees & Burdensome Requests
The court held that the circuit court erred in granting the defendant's motion to dismiss based on the FOIA undue-burden exemption. The appellate court found that the defendant failed to meet the…
- Johnson v. Joliet Police DepartmentFOIAAffirmedPersonnel & Student Records
The court affirmed the dismissal of the plaintiff's FOIA complaint, holding that the requested disciplinary records were exempt from disclosure under FOIA because they were protected by the Personnel…
- Marlon L. Watford v. Jamie Boyd and Bobbi WheelerFOIARule 23RemandedFOIA Response Process
The appellate court vacated the circuit court's sua sponte dismissal of the plaintiff's FOIA complaint. The court held that the dismissal was premature because it occurred before the defendants were…
- Martinez v. Cook County State’s Attorney’s OfficeFOIAAffirmedSearch & Production
The court affirmed summary judgment for the State's Attorney's Office, holding that the plaintiff's FOIA requests were improper because they sought the creation of new records rather than the…
- Sargent Shriver National Center on Poverty Law, Inc. v. Board of Education of the City of ChicagoFOIAAffirmedFees & Burdensome Requests
The court affirmed the dismissal of a FOIA complaint, holding that the plaintiff's request was unduly burdensome under section 7(1)(c) of FOIA. The court determined that the burden of compliance…
- Better Government Association v. Village of RosemontFOIAAffirmedGeneral Records Exemptions
The court held that the Village of Rosemont could not redact financial terms from public contracts under FOIA, as the trade secrets exemption (section 7(1)(g)) does not apply to standard rental rates…
- Calvin Merritte v. Thomas Templeton and Troy HollandFOIARule 23AffirmedFOIA Response Process
The circuit court did not err in refusing to consider claims that were barred by res judicata and beyond the scope of remand. The court further held that the plaintiff was not entitled to civil…
- City of Chicago v. Janssen Pharmaceuticals, Inc.FOIAAffirmedGeneral Records Exemptions
The court addressed a reverse-FOIA action where a pharmaceutical company sought to prevent the City of Chicago from disclosing documents provided under a protective order. The court affirmed the…
- Clarence Love v. Cook County State's Attorney's OfficeFOIARule 23AffirmedFOIA Response Process
The trial court properly granted summary judgment because the plaintiff's FOIA claim became moot after the defendant provided the requested information. The court also correctly denied the…
- Dole v. City of ChicagoFOIARule 23RemandedSearch & Production
The court affirmed the dismissal of the plaintiff's FOIA complaints and the denial of civil penalties and index requests. The case was remanded for the trial court to consider the plaintiff's request…
- Garlick v. Naperville TownshipFOIAAffirmedSearch & Production
The court affirmed the dismissal of a FOIA complaint where the plaintiff sought a real-property database in a specific native file format. The court held that the township satisfied its obligations…
- In re Appointment of Special ProsecutorFOIAAffirmedGeneral Records Exemptions
The Supreme Court held that judicial protective orders take precedence over FOIA disclosure requirements. Consequently, the City did not improperly withhold documents under section 11(d) of FOIA…
- Institute for Justice v. Department of Financial and Professional RegulationFOIARule 23ReversedGeneral Records Exemptions
The appellate court reversed the grant of summary judgment in favor of the plaintiff regarding a FOIA request. The court held that the law in effect at the time of the ruling exempted the disclosure…
- McGee v. KelleyFOIAAffirmedPolice & Investigative Records
The court affirmed the denial of a FOIA request for police records, holding that the records were exempt from disclosure under section 7(1)(c) as an unwarranted invasion of personal privacy. The…
- People v. HemphillFOIARule 23AffirmedFOIA Response Process
The court affirmed the dismissal of the defendant's petition for mandamus regarding a FOIA request. The court held that the defendant could not seek administrative review of a non-binding Public…
- Perry v. Department of Financial & Professional RegulationFOIAReversed in partGeneral Records Exemptions
The Supreme Court held that statutory amendments regarding the disclosure of professional regulation complaints were substantive rather than procedural and therefore applied prospectively.…
- Rogers v. Ammarell, et al.FOIARule 23AffirmedFOIA Response Process
The court affirmed the dismissal of the plaintiff's complaint, finding that her FOIA claim was rendered moot by her own waiver regarding the underlying board resolutions. The court held that because…
- The Chicago Tribune v. The College of Du Page and The College of Du Page FoundationFOIAAffirmedGeneral Records Exemptions
The court held that a federal grand jury subpoena served on the College of Du Page Foundation was subject to disclosure under FOIA, rejecting the argument that the subpoena was exempt as information…
- Warren R. Garlick v. Bloomingdale Township and Milton TownshipFOIARule 23AffirmedFOIA Response Process
The trial court properly dismissed the plaintiff's FOIA complaint as moot because the defendants provided the requested data in the format the plaintiff requested. The appellate court affirmed the…
- Allen v. Clark County Park District Board of CommissionersOMAReversedMeeting Notices & Agendas
The court held that the Board violated the Open Meetings Act by failing to provide a sufficient public recital of the nature of the matters being considered before voting on lease rates and…
- Better Government Ass’n v. Illinois High School Ass’nFOIAAffirmedPublic Body Definition
The Supreme Court held that the Illinois High School Association (IHSA) is not a 'public body' under the Illinois FOIA because it is a private, voluntary organization not created by government…
- Bocock v. MeyersFOIARule 23AffirmedSearch & Production
The appellate court affirmed the dismissal of a pro se FOIA complaint, holding that while the plaintiff sufficiently alleged a claim against the assistant state's attorney in his official capacity,…
- Brian Dugan v. Illinois Department of CorrectionsFOIARule 23AffirmedGeneral Records Exemptions
The appellate court affirmed the circuit court's grant of summary judgment in favor of the Department of Corrections regarding a FOIA request. The court held that the Department properly asserted a…
- Cebertowicz v. Illinois Department of CorrectionsFOIAAffirmedGeneral Records Exemptions
The court held that the Illinois Department of Corrections did not violate FOIA by denying an inmate's request for copies of documents that were already available for inspection in the facility's…
- For the Good of Illinois, Inc. v. Office of ComptrollerFOIARule 23AffirmedFees & Burdensome Requests
The appellate court affirmed the dismissal of the plaintiff's FOIA complaint, holding that the Comptroller properly established that the request was unduly burdensome. The court further affirmed the…
- Green v. Chicago Police DepartmentFOIAAffirmedFOIA Response Process
The Supreme Court held that the propriety of a public body's denial of a FOIA request must be measured at the time the agency asserts the exemption and denies the request, rather than accounting for…
- Hites v. Waubonsee Community CollegeFOIAReversed in partPublic Records Definition
The court held that data stored in a public body's existing databases constitutes a public record under FOIA, and retrieving such data does not constitute the creation of a new record. However,…
- John Kraft v. Arcola TownshipFOIARule 23AffirmedFOIA Response Process
The appellate court affirmed the trial court's judgment in favor of Arcola Township, finding that the plaintiff failed to present sufficient evidence to establish a prima facie case of a FOIA…
- Korner v. MadiganFOIAAffirmedPublic Body Definition
The court affirmed the dismissal of a FOIA complaint because the plaintiff named only individual state officials as defendants rather than the public body itself. The court held that the Illinois…
- Kowalski v. Cook County Officers Electoral BoardOMARule 23AffirmedMeeting Conduct & Participation
The court affirmed the trial court's grant of summary judgment in favor of the Electoral Board, finding no genuine issue of material fact regarding an alleged Open Meetings Act violation. The court…
- Lloyd Saterfield v. The Illinois Department of CorrectionsFOIARule 23RemandedFOIA Response Process
The court affirmed the dismissal of the plaintiff's FOIA complaint but remanded the case with directions for the Department of Corrections to unredact and disclose a specific portion of the requested…
- Naomi Lopez Bauman and The Illinois Policy Institute v. The Department of Central Management ServicesFOIARule 23Reversed in partFees & Burdensome Requests
The appellate court held that the trial court erred in finding the plaintiffs ineligible for attorney fees under FOIA. The court reversed the denial of fees and remanded the case for a determination…
- Peoria Journal Star v. City of PeoriaFOIAAffirmedGeneral Records Exemptions
The court held that a police department report regarding an employee grievance was not exempt from disclosure under FOIA section 7(1)(n). The court determined that because the report was created…
- Puryear v. Village of Prairie GroveFOIARule 23AffirmedFOIA Response Process
The court affirmed the trial court's exclusion of evidence regarding unrelated traffic stops and lay opinion testimony concerning computer error messages in a FOIA bad-faith claim. The court held…
- Ralph Mlaska v. The Illinois Department of CorrectionsFOIARule 23AffirmedGeneral Records Exemptions
The appellate court affirmed the trial court's ruling that the documents requested by the plaintiff from the Illinois Department of Corrections were exempt from disclosure under sections 7(1)(a),…
- Vernon Tolbert v. The Illinois State Police, Bruce Bialorucki, and Steven LyddonFOIARule 23DismissedSearch & Production
The appellate court affirmed the trial court's dismissal of the plaintiff's FOIA complaint. The court held that the plaintiff failed to allege sufficient facts to survive a section 2-615 motion to…
- Warren R. Garlick v. Naperville TownshipFOIARule 23Reversed and remandedFOIA Response Process
The trial court erred in dismissing the plaintiff's complaint for failure to state a violation of section 8.5 of the Freedom of Information Act. The court held that the question of whether a public…
- Watkins v. JohnsonFOIARule 23AffirmedSearch & Production
The court affirmed judgment for the defendants on the plaintiff's FOIA claims, finding that requested documents were not in the defendants' possession. Additionally, the court held that the record on…
- Board of Education of Springfield School District No. 186 v. Attorney GeneralOMAAffirmedClosed Sessions
The Supreme Court held that a public body's oral recital prior to a closed session vote sufficiently complied with the Open Meetings Act when it identified the general nature of the matter and the…
- Calvin Merritte v. Thomas Templeton and Troy HollandFOIARule 23Reversed in partPersonnel & Student Records
The court held that an inmate was not entitled to a correction officer's medical or disciplinary records under FOIA, but was entitled to a redacted photograph of the officer's injury. The court…
- Howard v. WeitekampFOIAAffirmedGeneral Records Exemptions
The court held that specific provisions of the Unified Code of Corrections and the Illinois Administrative Code regarding inmate access to master record files control over the general access…
- James Perdue v. Village of Tower HillFOIARule 23AffirmedFees & Burdensome Requests
The court affirmed the trial court's decision to award attorney fees to the requester after the Village of Tower Hill voluntarily produced records following a FOIA request. The court held that the…
- Kirk Allen v. Department of Healthcare and Family Services, and Julie HamosFOIARule 23AffirmedFOIA Response Process
The court affirmed the denial of the plaintiff's motion to reconsider his complaint for declaratory and injunctive relief, finding no abuse of discretion regarding newly discovered evidence. The…
- Shehadeh v. Office of Executive Inspector General for the Agencies of the Illinois GovernorFOIARule 23AffirmedFOIA Response Process
The appellate court affirmed summary judgment for the defendant because the plaintiff received the requested public record during the pendency of the FOIA action, rendering the request moot. The…
- Vernon Tolbert v. Office of Emergency Management Communications, City of Chicago, Jose A. Santiago and Dionne A. TateFOIARule 23AffirmedSearch & Production
The appellate court affirmed the dismissal of the plaintiff's FOIA complaint, finding that the defendants conducted an adequate search and properly informed the plaintiff that the requested…
- Ward v. WeisbaumFOIARule 23AffirmedGeneral Records Exemptions
The circuit court properly dismissed the plaintiff's FOIA lawsuit for injunctive relief because the requested home addresses of two individuals constituted private information exempt from disclosure…
- Better Government Association v. ZarubaFOIAAffirmedPolice & Investigative Records
The court affirmed the dismissal of a FOIA request seeking records of LEADS inquiries made by the sheriff's son. The court held that the plaintiff was not the proper entity to investigate alleged…
- Chicago Tribune Co. v. Department of Financial & Professional RegulationFOIAReversedSearch & Production
The court held that the Department of Financial and Professional Regulation was not required to comply with a FOIA request that necessitated the creation of a new record not currently maintained by…
- Gary Frederico Ellison v. Lisa MadiganFOIARule 23AffirmedPublic Body Definition
The appellate court affirmed the dismissal of the plaintiff's complaint because the Attorney General was not the public body to whom the FOIA requests were directed and did not possess the requested…
- John Peter Gonigam and First Electric Newspaper, LLC v. Office of the Sheriff of McHenry CountyFOIARule 23AffirmedGeneral Records Exemptions
The court affirmed the trial court's order requiring the Sheriff's Office to release documents, holding that the records were not exempt under section 7(1)(n) of the FOIA. The court determined the…
- Kalven v. City of ChicagoFOIAReversed in partPolice & Investigative Records
The appellate court held that police 'repeater lists' and complaint register files regarding officer misconduct are subject to disclosure under FOIA. The court affirmed summary judgment for the…
- Nord v. Village of SaybrookOMARule 23AffirmedMeeting Conduct & Participation
The appellate court affirmed the dismissal of the plaintiff's complaint, holding that the alleged Open Meetings Act violation was not related to the relief sought. The court further determined that a…
- P&S Grain, LLC v. Williamson CountyOMARule 23AffirmedMeeting Notices & Agendas
The circuit court did not err in finding that the county had not violated the Open Meetings Act, nor had it exceeded its authority in passing a resolution authorizing the imposition of a school…
- Rushton v. City of SpringfieldOMARule 23ReversedMeeting Conduct & Participation
The appellate court held that the trial court lacked jurisdiction to order the defendants to record committee meetings because the underlying action had been dismissed in May 2012. Consequently, the…
- Sage Information Services v. SuhrFOIAAffirmedFees & Burdensome Requests
The court held that when a FOIA requester seeks electronic records, a public body is limited by section 6 of the FOIA to charging only the actual cost of the electronic media used. The court ruled…
- Taiym v. Retirement Board of the Policemen’s Annuity & Benefit FundOMAAffirmedMeeting Conduct & Participation
The court addressed whether the Board violated the Open Meetings Act by failing to adopt a pension decision via an open vote on a written document. While the court noted that best practices require…
- Uptown People's Law Center v. Department of CorrectionsFOIAAffirmedFees & Burdensome Requests
The court held that while court-ordered relief is not a prerequisite for attorney fees under FOIA, a not-for-profit organization is not entitled to fees when it did not actually incur costs because…
- Brown v. GrosskopfFOIAAffirmedPublic Body Definition
The appellate court affirmed the dismissal of the State's Attorney's complaint seeking a declaratory judgment on whether his office constitutes a 'public body' under FOIA. The court held that no…
- City of Champaign v. MadiganFOIAReversed in partFees & Burdensome Requests
The court held that electronic communications sent by city council members regarding public business during meetings are subject to FOIA disclosure. However, the court reversed the award of attorney…
- Dumke v. City of ChicagoFOIAReversedGeneral Records Exemptions
The court held that the City of Chicago waived the FOIA exemption under section 7(1)(f) for a consultant's report when the mayor publicly cited and identified the report in a press conference and…
- Fagel v. Department of TransportationFOIAAffirmedSearch & Production
The court held that the Department of Transportation was required to provide the requested information in an unlocked electronic spreadsheet format under FOIA. The court further affirmed the award of…
- Garlick v. Office of the Public Access CounselorFOIAAffirmed in partFOIA Response Process
The court held that a nonbinding opinion from the Public Access Counselor (PAC) is not subject to the Administrative Review Law. Consequently, a requester may sue a public body directly under section…
- Howe v. Retirement Board of the Firemen's Annuity & Benefit FundOMAReversedMeeting Conduct & Participation
The court held that the Retirement Board failed to take valid final action in compliance with the Open Meetings Act regarding the denial of the plaintiff's disability benefits. Consequently, the…
- Hughes v. RickerFOIARule 23AffirmedFOIA Response Process
The court held that the public interest exception to the mootness doctrine did not apply to a former school board member's FOIA-related claim because she failed to allege a general policy of denial.…
- Lawrence v. WilliamsOMADismissedMeeting Conduct & Participation
The appellate court dismissed the appeal for lack of jurisdiction because the electoral board violated the Open Meetings Act by issuing disqualification decisions at meetings that lacked a quorum.…
- Lucas v. Prisoner Review BoardFOIAAffirmedGeneral Records Exemptions
The court affirmed the dismissal of a FOIA complaint filed by a prisoner seeking records from the Prisoner Review Board and the Department of Corrections. The court held that the requested records…
- Nelson v. Kendall CountyFOIAReversedPublic Body Definition
The Illinois Supreme Court held that the office of a State's Attorney is part of the executive branch and constitutes a public body subject to the disclosure requirements of the Freedom of…
- Roxana Community Unit School District No. 1 v. Environmental Protection AgencyFOIA + OMAReversed in partClosed Sessions
The court held that the Environmental Protection Agency violated FOIA by failing to comply with document requests and the Pollution Control Board violated the Open Meetings Act by conducting improper…
- Shehadeh v. MadiganFOIAAffirmedFees & Burdensome Requests
The court affirmed summary judgment for the Attorney General, holding that a FOIA request requiring the review of 9,200 records was unduly burdensome under section 3(g). The court found that the…
- The State Journal-Register and Bruce Rushton v. The University of Illinois Springfield and Harry BermanFOIAReversed in partPersonnel & Student Records
The court held that the trial court erred in denying the plaintiffs' FOIA request for specific redacted documents, including an email string, internal communications, and witness statements, as they…
- Uphoff v. GrosskopfFOIAReversedPublic Body Definition
The appellate court reversed the trial court's order, holding that the State's Attorney's office is not a 'public body' for the purposes of the Freedom of Information Act and is therefore exempt from…
- Warren R. Garlick v. Lisa MadiganFOIARule 23AffirmedFOIA Response Process
The court affirmed the dismissal of the plaintiff's FOIA complaint, finding that the plaintiff had explicitly stated he did not seek the redacted information in his initial request. The court further…
- Gupta v. Illinois Department of Financial and Professional RegulationOMARule 23AffirmedMeeting Conduct & Participation
The court affirmed the denial of a stay, holding that the Board acted with proper authority because a quorum was present and a majority voted on the recommendations. The court rejected the…
- Heinrich v. WhiteFOIAReversed in partFees & Burdensome Requests
The court reversed the dismissal of a FOIA request for administrative license revocation notices, holding that the trial court should have considered whether the plaintiff wanted the records with…
- Mental Health America of Illinois v. Illinois Department of Healthcare and Family ServicesOMARule 23AffirmedPublic Body Definition
The court affirmed the dismissal of a mandamus petition, holding that the Drug and Therapeutics Committee of the Illinois State Medical Society is not a 'public body' subject to the Open Meetings…
- Parker v. NichtingOMAReversed in partFees & Burdensome Requests
The court held that while the plaintiff was entitled to attorney fees for a successful Open Meetings Act claim, the trial court abused its discretion by reducing the fee award without sufficient…
- Rock River Times v. Rockford Public School District 205FOIAAffirmedFOIA Response Process
The court held that the plaintiff was not a prevailing party entitled to attorney fees because the school disclosed the requested records before a court order. However, the court affirmed the…
- Roxana Community Unit School District No. 1 v. WRB Refining, LPOMAAffirmed in partMeeting Conduct & Participation
The court affirmed a preliminary injunction against the Pollution Control Board regarding Open Meetings Act violations, but modified the order to remove specific restrictions on meetings concerning…
- Sage Information Services v. HummFOIAReversed in partFees & Burdensome Requests
The court held that FOIA, rather than the Property Tax Code, governs fees for electronic property assessment records. The court reversed the denial of the request to the assessment officer but…
- Watkins v. McCarthyFOIAReversed and remandedPolice & Investigative Records
The appellate court reversed the dismissal of an inmate's FOIA request for police misconduct records. The court remanded the case for an in camera inspection to determine the applicability of FOIA…
- LeCompte v. Zoning Board of AppealsOMAAffirmedClosed Sessions
The plaintiffs raised an Open Meetings Act claim regarding closed session procedures for the first time on appeal. The court held that the issue was forfeited because it was not raised before the…
- Taliani v. HerrmannFOIAReversedPublic Records Definition
The appellate court reversed an order awarding attorney fees under the Freedom of Information Act, holding that the Act is not the proper legal vehicle for obtaining grand jury transcripts from a…
- Berge v. HeilmannOMARule 23AffirmedClosed Sessions
The appellate court affirmed the circuit court's ruling that the Village of Oak Lawn did not violate the Open Meetings Act during a closed session. The court held that the discussions were…
- In re Petition to Disconnect Certain Territory (Foxfield Subdivision) v. Village of Campton HillsOMARule 23AffirmedMeeting Notices & Agendas
The court affirmed the dismissal of a petition to disconnect territory, holding that the Village's meeting agenda and procedures did not violate the Open Meetings Act. The court found that the…
- Rockford Police Benevolent and Protective Association, Unit #6 v. MorrisseyFOIARule 23AffirmedFees & Burdensome Requests
The court affirmed the trial court's grant of summary judgment in favor of the plaintiff, compelling the disclosure of survey results under FOIA. The court further held that the trial court did not…
- Sage Information Services and Roger W. Hurlbert v. David HendersonFOIARule 23AffirmedGeneral Records Exemptions
The court affirmed the dismissal of a FOIA complaint, holding that section 9-20 of the Property Tax Code acts as a specific statutory bar to the disclosure of the requested property tax records. The…
- Stern v. Wheaton-Warrenville Community Unit School District 200FOIARule 23Reversed in partGeneral Records Exemptions
The Supreme Court held that a school superintendent's employment contract is not exempt from disclosure under FOIA as a personnel file, as it constitutes a contract dealing with the expenditure of…
- Gekas v. WilliamsonFOIARule 23Reversed in partPolice & Investigative Records
The court held that records concerning allegations of misconduct by a deputy sheriff in the performance of his public duties are not exempt from disclosure under the FOIA personnel file exemption.…
- Kopchar v. City of ChicagoFOIARule 23AffirmedGeneral Records Exemptions
The court held that the City of Chicago was not required under FOIA to disclose the specific criteria or standards used to evaluate firefighter physical abilities tests. The court affirmed the…
- National Association of Criminal Defense Lawyers v. Chicago Police DepartmentFOIARule 23OtherPolice & Investigative Records
The court addressed whether data used for a legislatively mandated study on eyewitness identification procedures was subject to disclosure under FOIA. The case involved consolidated appeals regarding…
- Newman, Raiz and Shelmadine, LLC v. BrownFOIARule 23Reversed in partSearch & Production
The court addressed whether the Clerk of the Circuit Court could prohibit the use of portable scanners to copy public records under FOIA. The appellate court held that the Clerk must permit the use…
- Wyman v. SchweighartOMARule 23AffirmedClosed Sessions
The court affirmed summary judgment for the defendants, holding that the Open Meetings Act does not explicitly prohibit a public body from inviting non-members to attend a closed session. The court…
- DesPain v. City of CollinsvilleFOIARule 23Reversed in partFOIA Response Process
The plaintiff appealed a summary judgment regarding his FOIA requests to the City of Collinsville. The appellate court affirmed in part and reversed in part the circuit court's ruling concerning the…
- Sage Information Services and Roger W. Hurlbert v. Gary A. King, Du Page County ClerkFOIARule 23Reversed and remandedFees & Burdensome Requests
The court held that the trial court erred in granting a motion to dismiss because the defendant failed to provide a factual basis to establish that the $5,500 fee charged for a database compilation…
- Galena Gazette Publications, Inc. v. County of Jo DaviessOMARule 23ReversedClosed Sessions
The appellate court held that the defendants' closed sessions were properly conducted under the real estate acquisition exception of the Open Meetings Act (5 ILCS 120/2(c)(5)). Consequently, the…
- Kibort v. WestromFOIARule 23AffirmedGeneral Records Exemptions
The court held that the Du Page County Election Commission properly denied a FOIA request for election materials because the Election Code (10 ILCS 5/17-20, 17-22) specifically prohibited their…
- Feret v. SchillerstromOMARule 23Reversed in partMeeting Notices & Agendas
The court addressed whether the Du Page County Board violated the Open Meetings Act by enacting a resolution without proper agenda notice. While the court previously allowed the claim to proceed,…
- McKee v. The Board of Trustees of the Champaign Police Pension FundOMARule 23AffirmedClosed Sessions
The court affirmed the denial of disability benefits, holding that the Board did not violate the Open Meetings Act by holding a closed session pursuant to its rules and regulations. The court found…
- Ebert v. ThompsonFOIAAffirmedFees & Burdensome Requests
The court affirmed the denial of attorney fees, holding that because the plaintiff explicitly disclaimed proceeding under the Freedom of Information Act at the trial level, she could not invoke the…
- Lieber v. Southern Illinois UniversityFOIAReversed in partFOIA Response Process
The court held that Southern Illinois University failed to meet its burden of proving that requested freshman housing inquiry records were exempt from disclosure under the Freedom of Information Act.…
- Twin-Cities Broadcasting Corp. v. ReynardFOIAAffirmedGeneral Records Exemptions
The court held that a government entity with a substantial interest in requested documents may assert a FOIA exemption even if the entity currently in possession of the documents refuses to do so.…
- Board of Education of Community Unit School District No. 337 v. Board of Education of Community Unit School District No. 338OMAAffirmedMeeting Notices & Agendas
The court held that the Regional Board of School Trustees did not violate the Open Meetings Act regarding notice requirements for a rescheduled meeting. The court found that the Board provided…
- Freedom Oil Company v. The Pollution Control BoardOMAAffirmedMeeting Conduct & Participation
The court addressed whether the Pollution Control Board could conduct a meeting via telephone conference call under the Open Meetings Act. The court held that the Board had the authority to conduct…
- Local 1274, Illinois Federation of Teachers v. Niles Township High School, District 219FOIAReversedFOIA Response Process
The appellate court reversed a summary judgment that had required the plaintiff to exhaust collective bargaining grievance procedures before seeking records under the Freedom of Information Act. The…
- Paxson v. Board of Education of School District No. 87OMAAffirmedOther
The court affirmed the dismissal of a complaint alleging violations of the Open Meetings Act, holding that the plaintiffs failed to file their action within the 45-day statute of limitations. The…
- The Copley Press, Inc. v. Administrative Office of the CourtsFOIAReversed in partPublic Body Definition
The court held that the Administrative Office of the Courts and its related pretrial services agencies are part of the judiciary and therefore not subject to the Illinois Freedom of Information Act.…
- Cooper v. Department of the LotteryFOIAAffirmedGeneral Records Exemptions
The court affirmed the denial of a FOIA request for lottery vendor sales data, holding that the information was exempt from disclosure under the personal privacy exemption of the Illinois FOIA. The…
- Copley Press, Inc. v. City of SpringfieldFOIAAffirmedPersonnel & Student Records
The court held that records of an internal investigation into sexual harassment allegations against a police chief were exempt from disclosure under the FOIA exemption for personal information that…
- Cremer v. City of Macomb Board of Fire and Police CommissionersFOIAReversed in partPublic Records Definition
The court distinguished the Freedom of Information Act from the plaintiff's discovery request, noting that the plaintiff sought his own examination results for litigation purposes rather than public…
- Schessler v. Department of ConservationFOIAAffirmedGeneral Records Exemptions
The court affirmed the circuit court's order requiring the Department of Conservation to disclose requested records. The court held that the Department failed to meet its burden of proving that…
- Wayne County Press, Inc. v. Georgia IsleFOIARemandedGeneral Records Exemptions
The court held that the trial court applied an incorrect burden of proof regarding the defendant's claim that marriage license applications were exempt from FOIA disclosure under the Vital Records…
- Carbondale Convention Center, Inc. v. City of CarbondaleFOIAReversedGeneral Records Exemptions
The court held that a trial court's confidentiality order (gag order) does not constitute 'State law' under the FOIA exemption for information specifically prohibited from disclosure by federal or…
- David Blumenfeld, Ltd. v. Department of Professional RegulationFOIAAffirmedGeneral Records Exemptions
The court held that notices of disciplinary conferences sent by the Department of Professional Regulation to licensees are exempt from disclosure under FOIA. The court determined that the names and…
- Hopf v. Topcorp, Inc.FOIA + OMAAffirmedPublic Body Definition
The court held that two private, for-profit corporations created by the City of Evanston and Northwestern University were not 'public bodies' subject to the Open Meetings Act or FOIA. The court…
- Moscardini v. County Officers Electoral Board of Du Page CountyOMAReversedClosed Sessions
The plaintiff challenged an electoral board's decision to remove his name from the ballot, alleging, among other things, that the board violated the Open Meetings Act by conducting deliberations in…
- Osran v. BusFOIAReversedGeneral Records Exemptions
The court held that documents related to a county's solid waste management plan were not exempt from disclosure under the Freedom of Information Act. The court ordered the defendants to produce the…
- Williams v. KlincarFOIAReversed in partFOIA Response Process
The court held that the Prisoner Review Board failed to provide an adequate justification for denying a FOIA request for a parole progress report. The case was remanded for an in camera inspection to…
- Workmann v. Illinois State Board of EducationFOIAAffirmedFees & Burdensome Requests
The court held that a plaintiff does not 'substantially prevail' under the FOIA for the purpose of recovering attorney fees when the requested records do not exist and the public body was under no…
- Board of Education School District No. 67 v. SikorskiOMAReversed in partClosed Sessions
The court held that the Board violated the Open Meetings Act by holding an executive session to discuss the postponement of a property sale. However, the court determined that the violation was cured…
- People ex rel. Ryan v. Village of Villa ParkOMAReversedClosed Sessions
The court held that the Village of Villa Park violated the Open Meetings Act by holding closed sessions to discuss matters, such as traffic and infrastructure improvements, that did not fall under…
- Quinn v. StoneFOIAAffirmedPublic Body Definition
The court held that an individual alderman of the City of Chicago does not constitute a "public body" as defined under the Illinois Freedom of Information Act. Consequently, the court affirmed the…
- Scott v. Illinois State Police Merit BoardOMAAffirmedClosed Sessions
The court held that the Board's meeting to discuss disciplinary action against the plaintiff fell within the Open Meetings Act exception for considering information regarding the employment or…
- American Federation of State, County & Municipal Employees v. County of CookFOIAAffirmedSearch & Production
The Supreme Court held that under the Illinois Freedom of Information Act, a public body is not required to provide public records in a specific electronic format (computer tape) if it provides the…
- CBS, Inc. v. ParteeFOIAAffirmedPersonnel & Student Records
The court held that the race of assistant State's Attorneys, as recorded in personnel files, is exempt from disclosure under the Illinois FOIA because its release would constitute an unwarranted…
- Healey v. Teachers Retirement SystemFOIAAffirmedGeneral Records Exemptions
The court affirmed the denial of a FOIA request for detailed enrollee information, including names, addresses, and pension data. The court held that the requested information was exempt from…
- Safanda v. Zoning Board of Appeals of the City of GenevaOMAReversed in partMeeting Conduct & Participation
The court addressed whether the trial court erred in dismissing counts of the plaintiff's complaint alleging violations of the Open Meetings Act. The appellate court held that the trial court…
- Stratton v. Wenona Community Unit District No. 1OMAReversedMeeting Conduct & Participation
The court addressed allegations of Open Meetings Act violations during a student expulsion proceeding. The Supreme Court held that the purpose of the Act was upheld because the plaintiffs were…
- Swanson v. The Board of Police Commissioners of the Village of Lake in the HillsOMAAffirmedClosed Sessions
The court held that the Open Meetings Act does not provide a private cause of action for the disclosure of information from a closed session. Consequently, the trial court's dismissal of the…
- American Federation of State, County and Municipal Employees (AFSCME) v. County of CookFOIAReversedSearch & Production
The court addressed whether a public body is required to provide requested public records in a specific electronic format (computer tape) rather than a printed format. The court held that the…
- Baudin v. City of Crystal LakeFOIAReversedFOIA Response Process
The appellate court held that the trial court erred in granting summary judgment to the City without conducting an in camera inspection of the disputed records. The court emphasized that trial courts…
- Bowie v. Evanston Community Consolidated School District No. 65FOIAReversedSearch & Production
The Supreme Court held that the Freedom of Information Act does not require a public body to create new records or manipulate existing computer data to redact exempt information. The court ruled that…
- Gosnell v. HoganOMAAffirmedClosed Sessions
The court affirmed the denial of an injunction against a school board, holding that topics not specifically excepted under the Open Meetings Act may be discussed in closed session if they are germane…
- Hamer v. LentzFOIAReversed in partFees & Burdensome Requests
The Supreme Court held that records held by the General Assembly Retirement System are subject to disclosure under FOIA. However, the Court further ruled that an attorney representing themselves pro…
- Kenyon v. GarrelsFOIAAffirmedFOIA Response Process
The court held that the Freedom of Information Act does not require a public body to answer interrogatory-style questions or create new records to satisfy a request. Furthermore, the court found that…
- Margolis v. Director of the Department of RevenueFOIAReversed in partGeneral Records Exemptions
The court held that the trial court failed to perform the necessary balancing test to determine if the requested business registration information constituted a clearly unwarranted invasion of…
- Staske v. City of ChampaignFOIAReversedPolice & Investigative Records
The court held that witness names, addresses, and statements contained in a police traffic accident report are exempt from disclosure under section 7(b)(v) of the FOIA. The court reversed the trial…
- Bowie v. Evanston Community Consolidated School District 65FOIAReversed in partFOIA Response Process
The court held that the school district must provide requested test score records after redacting personally identifiable information, as masking such data does not constitute the creation of a new…
- Griffith Laboratories U.S.A. v. The Metropolitan Sanitary District of ChicagoFOIAAffirmedGeneral Records Exemptions
The court held that sampling data and calculations compiled by the Metropolitan Sanitary District were exempt from disclosure under the FOIA's investigatory records exemption. Disclosure was denied…
- Hamer v. LentzFOIAReversed in partFees & Burdensome Requests
The court held that an attorney representing themselves in a FOIA action is not barred from recovering reasonable attorney fees under the Illinois FOIA. The case was remanded to the trial court to…
- Hopf v. Topcorp, Inc.FOIA + OMAAffirmedPublic Body Definition
The court held that the defendant for-profit corporations were not 'subsidiary bodies' of the City of Evanston and therefore were not subject to the requirements of the Open Meetings Act or the…
- Argo High School Council of Local 571 v. Argo Community High School District 217OMAAffirmedMeeting Notices & Agendas
The court held that the school board's meeting held on a legal holiday complied with the Open Meetings Act, as the notice provided was sufficient and the actions taken were germane to the agenda.…
- Hoffman v. Department of CorrectionsFOIAAffirmedGeneral Records Exemptions
The court held that information regarding the procedures and drugs used by the Department of Corrections for lethal injection executions is subject to disclosure under FOIA. The court reasoned that…
- Illinois Educational Labor Relations Board v. Homer Community Consolidated School District No. 208FOIA + OMAReversedFOIA Response Process
The court held that the Illinois Educational Labor Relations Board lacked the implied authority to order discovery of documents related to collective bargaining negotiations. The court reasoned that…
- Pecora Oil Company v. JohnsonFOIAAffirmedGeneral Records Exemptions
The court affirmed the trial court's order compelling the Department of Revenue to produce records under the FOIA. The court held that the records were not exempt from disclosure under the Retailers'…
- Wayne Township Board of Auditors v. LudwigFOIAReversed in partFees & Burdensome Requests
The case concerns a dispute over attorney fees following a mandamus action regarding access to township records; while the underlying dispute involved FOIA-related access to public records, the…
- Carrigan v. HarkraderFOIAReversed in partGeneral Records Exemptions
The court held that the Freedom of Information Act applies to records regardless of whether they were created before or after the Act's effective date. However, the court affirmed the denial of the…
- City of Monmouth v. Galesburg Printing and Publishing Co.FOIAAffirmedGeneral Records Exemptions
The court held that the City of Monmouth failed to state a cause of action because it did not allege that the specific requested information constituted a clearly unwarranted invasion of personal…
- Smith v. Cook County Probation DepartmentFOIAAffirmedGeneral Records Exemptions
The court affirmed the dismissal of a FOIA request for probation records, holding that such records are not public records under the FOIA because they are specifically protected from disclosure by…
- The Copley Press, Inc. v. The City of SpringfieldFOIAReversed in partGeneral Records Exemptions
The court held that the plaintiff did not have a First Amendment right to access the specific public records sought under the Freedom of Information Act. The appellate court reversed the trial…
- People ex rel. Hartigan v. Illinois Commerce CommissionOMAAffirmedOther
The court affirmed the dismissal of an Open Meetings Act complaint, holding that the case was moot because the underlying meeting had already occurred and no exceptions to the mootness doctrine…
- Lindsey v. Board of Education of the City of ChicagoOMAReversed in partMeeting Conduct & Participation
The court held that a trial court's preliminary injunction against the Board of Education was overbroad because it prohibited the Board from exercising its lawful power of appointment. The court…
- PJS Enterprises v. KlincarOMAAffirmedMeeting Conduct & Participation
The court affirmed the denial of a prisoner's motion to intervene in a lawsuit brought by a newspaper seeking access to parole hearings under the Open Meetings Act. The court held that the trial…
- Potter v. JudgeOMAAffirmedOther
The court affirmed the dismissal of a complaint alleging violations of the Open Meetings Act, holding that applying amendments to the Act retroactively would unconstitutionally impair vested contract…
- Richardson v. DunbarOMAAffirmedMeeting Conduct & Participation
The court referenced the Open Meetings Act to clarify that the statute encourages open meetings and does not mandate closed sessions for hearing complaints against employees. The OMA was cited only…
- WSDR, Inc. v. Ogle CountyOMAAffirmedMeeting Conduct & Participation
The court held that the Open Meetings Act requires public bodies to conduct votes openly rather than by secret ballot. While the court affirmed the order for disclosure of the votes, it noted that…
- People ex rel. Byron v. Board of Trustees of Southern Illinois UniversityOMAReversedMeeting Conduct & Participation
The court held that a labor organization did not have a right to intervene in a mandamus and declaratory judgment action brought by a State's Attorney against a public body for alleged Open Meetings…
- People ex rel. Difanis v. BarrOMAAffirmedClosed Sessions
The Supreme Court affirmed the lower courts' rulings that the Urbana city council violated the Open Meetings Act by holding a private meeting of a majority of its members to discuss public business.…
- People ex rel. Difanis v. BarrOMAReversedPublic Body Definition
The court addressed whether a caucus of city council members constituted a meeting of a public body under the Open Meetings Act. The court held that the Act applies to meetings of legislative,…
- Davis v. Board of Education of Farmer City-Mansfield Community Unit School District No. 17OMAAffirmedClosed Sessions
The court addressed whether a school board violated the Open Meetings Act by holding a closed session to discuss the superintendent's employment. The court held that the board's actions regarding the…
- Rockford Newspapers, Inc. v. Northern Illinois Council on Alcoholism and Drug DependenceOMAAffirmedPublic Body Definition
The court held that a private, not-for-profit corporation receiving government funding and subject to government regulation is not a 'public body' subject to the Open Meetings Act. The court reasoned…
- Pope v. ParkinsonOMAReversed in partPublic Body Definition
The court held that the University of Illinois Assembly Hall Advisory Committee was not subject to the Open Meetings Act because it functioned as an advisory body rather than a decision-making body.…
- People v. Board of Education of District 170OMAReversedClosed Sessions
The court addressed whether a school board violated the Open Meetings Act by holding a closed session to discuss employment contracts. The appellate court reversed the trial court's ruling, holding…
- Haight v. Board of Education of Community Unit School District No. 205OMAAffirmedClosed Sessions
The court addressed whether a school board violated the Open Meetings Act by taking final action to dismiss a teacher during an executive session. The court affirmed the dismissal of the plaintiff's…
- People ex rel. Cooper v. CarlsonOMAAffirmedPublic Body Definition
The court held that the Open Meetings Act applies to meetings of public bodies, such as committees and boards, but does not extend to voluntary meetings of staff or department heads who meet to…
- People ex rel. Hopf v. BargerOMAAffirmedClosed Sessions
The court affirmed a mandamus order requiring city officials to comply with the Open Meetings Act regarding the disclosure of minutes and notes from a closed executive session. The court held that…
- Illinois News Broadcasters Association v. City of SpringfieldOMADismissedMeeting Conduct & Participation
The court dismissed the appeal as moot because the underlying personnel issues were resolved and the statutory requirements for open meetings had been clarified by subsequent legislative amendments.…