Can they withhold this?
Every FOIA exemption (5 ILCS 140/7) and OMA exception (5 ILCS 120/2(c)) that appears in this corpus, in plain language, with how often the Public Access Counselor has actuallyupheld vs. rejected a withholding that invoked it. Use this to gauge whether a public body's stated reason is likely to hold up — then read the linked opinions for the real analysis.
Not legal advice, and not a per-exemption ruling. The upheld/rejected count below reflects each document's overall disposition, not a finding specific to that one exemption — a single opinion can discuss several exemptions while the PAC's disposition covers the case as a whole. Treat these counts as a directional signal, not a precedent count. See theFAQ disclaimer.
FOIA exemptions — 5 ILCS 140/7
2.15(c)Arrest-report details may be withheld if disclosure would interfere with law enforcement, endanger safety, or compromise facility security0 upheld1 rejected1 total
Arrest-report details may be withheld if disclosure would interfere with law enforcement, endanger safety, or compromise facility security
0 upheld (no violation found) · 1 rejected (violation found), out of 1 documents citing this exemption.
Example documents
3(g)Unduly burdensome categorical request1 upheld1 rejected2 total
Unduly burdensome categorical request (may be denied if it can't be narrowed and the burden outweighs the public interest)
1 upheld (no violation found) · 1 rejected (violation found), out of 2 documents citing this exemption.
Example documents
7General exemptions provision0 upheld3 rejected3 total
General exemptions provision (cites Sec. 7 as a whole without naming a specific subsection)
0 upheld (no violation found) · 3 rejected (violation found), out of 3 documents citing this exemption.
Example documents
7.5Exempt under another statute0 upheld0 rejected1 partial1 total
Exempt under another statute (cites Sec. 7.5's cross-reference list as a whole without naming a specific subsection)
0 upheld (no violation found) · 0 rejected (violation found) · 1 partial violation, out of 1 documents citing this exemption.
Example documents
7.5(bb)Statutorily-confidential record set referenced via Sec. 7.5(bb)2 upheld0 rejected4 total
Statutorily-confidential record set referenced via Sec. 7.5(bb)
2 upheld (no violation found) · 0 rejected (violation found) · 2 closed / insufficient info / other, out of 4 documents citing this exemption.
Example documents
7.5(cc)Law enforcement body-camera recordings10 upheld1 rejected11 total
Law enforcement body-camera recordings
10 upheld (no violation found) · 1 rejected (violation found), out of 11 documents citing this exemption.
Example documents
- Police body-camera recordings of a dispatch incident
- Police body-camera recordings of a traffic crash
- Body-camera footage and 911 recordings of a YMCA incident
- Police body-camera footage of a public encounter
- Police body and dash camera footage of a traffic accident
- Police body-camera footage of a private meeting between officers
7.5(h)Exempt under the State Officials and Employees Ethics Act1 upheld0 rejected1 total
Exempt under the State Officials and Employees Ethics Act (including inspector general office records)
1 upheld (no violation found) · 0 rejected (violation found), out of 1 documents citing this exemption.
Example documents
7.5(k)Law enforcement officer or driver identification info compiled under the Illinois Vehicle Code1 upheld0 rejected1 total
Law enforcement officer or driver identification info compiled under the Illinois Vehicle Code
1 upheld (no violation found) · 0 rejected (violation found), out of 1 documents citing this exemption.
Example documents
7.5(q)Statutorily-confidential record set referenced via Sec. 7.5(q)0 upheld3 rejected5 total
Statutorily-confidential record set referenced via Sec. 7.5(q)
0 upheld (no violation found) · 3 rejected (violation found) · 2 closed / insufficient info / other, out of 5 documents citing this exemption.
Example documents
7.5(r)Statutorily-confidential record set referenced via Sec. 7.5(r)0 upheld1 rejected5 total
Statutorily-confidential record set referenced via Sec. 7.5(r)
0 upheld (no violation found) · 1 rejected (violation found) · 4 closed / insufficient info / other, out of 5 documents citing this exemption.
Example documents
7.5(v)Statutorily-confidential record set referenced via Sec. 7.5(v)1 upheld0 rejected2 total
Statutorily-confidential record set referenced via Sec. 7.5(v)
1 upheld (no violation found) · 0 rejected (violation found) · 1 closed / insufficient info / other, out of 2 documents citing this exemption.
Example documents
7.5(w)Personally identifiable toll-account info exempted under the Toll Highway Act0 upheld1 rejected1 total
Personally identifiable toll-account info exempted under the Toll Highway Act
0 upheld (no violation found) · 1 rejected (violation found), out of 1 documents citing this exemption.
Example documents
7.5(y)Statutorily-confidential record set referenced via Sec. 7.5(y)2 upheld0 rejected2 total
Statutorily-confidential record set referenced via Sec. 7.5(y)
2 upheld (no violation found) · 0 rejected (violation found), out of 2 documents citing this exemption.
Example documents
7.5(zz)Statutorily-confidential record set referenced via Sec. 7.5(zz)2 upheld0 rejected3 total
Statutorily-confidential record set referenced via Sec. 7.5(zz)
2 upheld (no violation found) · 0 rejected (violation found) · 1 closed / insufficient info / other, out of 3 documents citing this exemption.
Example documents
7(1)General exemption list0 upheld2 rejected2 total
General exemption list (cites the lettered exemptions in Sec. 7(1) without naming a specific one)
0 upheld (no violation found) · 2 rejected (violation found), out of 2 documents citing this exemption.
Example documents
7(1)(a)Federal/State-law confidentiality — or public defender case files, for documents issued under the other amendment version16 upheld23 rejected5 partial54 total
Federal/State-law confidentiality — or public defender case files, for documents issued under the other amendment version (see Sec. 7)
16 upheld (no violation found) · 23 rejected (violation found) · 5 partial violation · 10 closed / insufficient info / other, out of 54 documents citing this exemption.
Example documents
- Email attachments between school board members
- A mayor's termination letter to a village clerk
- Police reports of an incident at a high school
- A private attorney's letter to a city law department
- Police records of uncharged sexual offense allegations against minors
- Subpoenas received by a police department
7(1)(b-5)Law-enforcement databases tracking an individual's physical/mental status0 upheld0 rejected1 partial1 total
Law-enforcement databases tracking an individual's physical/mental status
0 upheld (no violation found) · 0 rejected (violation found) · 1 partial violation, out of 1 documents citing this exemption.
Example documents
7(1)(b)Private information13 upheld56 rejected11 partial88 total
Private information (defined in Sec. 2(c-5) -- e.g. SSNs, driver's license numbers, home addresses in some contexts)
13 upheld (no violation found) · 56 rejected (violation found) · 11 partial violation · 8 closed / insufficient info / other, out of 88 documents citing this exemption.
Example documents
- A termination letter for a public employee
- A police officer's separation records
- A police department's case/incident report and related records
- Redaction of personal phone numbers from 911 audio
- Applications for a village board vacancy
- Police records of uncharged sexual offense allegations against minors
7(1)(c)Personal privacy19 upheld71 rejected16 partial114 total
Personal privacy (records whose release would be a clearly unwarranted invasion of personal privacy)
19 upheld (no violation found) · 71 rejected (violation found) · 16 partial violation · 8 closed / insufficient info / other, out of 114 documents citing this exemption.
Example documents
- A termination letter for a public employee
- Correspondence between a former city official and a contractor regarding contracts, later forwarded to an attorney
- A police officer's separation records
- A mayor's termination letter to a village clerk
- Records identifying officers flagged under Brady/Giglio protocols
- Settlement agreements for legal counsel payments
7(1)(d-5)Shared-system law-enforcement records the responding agency didn't create0 upheld1 rejected1 total
Shared-system law-enforcement records the responding agency didn't create
0 upheld (no violation found) · 1 rejected (violation found), out of 1 documents citing this exemption.
Example documents
7(1)(d-7)Automatic license plate reader data0 upheld0 rejected1 total
Automatic license plate reader data
0 upheld (no violation found) · 0 rejected (violation found) · 1 closed / insufficient info / other, out of 1 documents citing this exemption.
Example documents
7(1)(d)Law-enforcement/administrative-proceeding records1 upheld15 rejected17 total
Law-enforcement/administrative-proceeding records (general)
1 upheld (no violation found) · 15 rejected (violation found) · 1 closed / insufficient info / other, out of 17 documents citing this exemption.
Example documents
- A termination letter for a public employee
- Resignation and termination paperwork for police officers
- Video surveillance footage from an animal control facility
- Police reports on a missing person's death
- A police department's case/incident report and related records
- Redaction of personal phone numbers from 911 audio
7(1)(d)(i)Would interfere with pending/contemplated law-enforcement proceedings3 upheld8 rejected12 total
Would interfere with pending/contemplated law-enforcement proceedings
3 upheld (no violation found) · 8 rejected (violation found) · 1 closed / insufficient info / other, out of 12 documents citing this exemption.
Example documents
7(1)(d)(ii)Would interfere with active administrative enforcement proceedings3 upheld2 rejected2 partial8 total
Would interfere with active administrative enforcement proceedings
3 upheld (no violation found) · 2 rejected (violation found) · 2 partial violation · 1 closed / insufficient info / other, out of 8 documents citing this exemption.
Example documents
7(1)(d)(iii)Would create a substantial likelihood of an unfair trial or hearing0 upheld4 rejected2 partial7 total
Would create a substantial likelihood of an unfair trial or hearing
0 upheld (no violation found) · 4 rejected (violation found) · 2 partial violation · 1 closed / insufficient info / other, out of 7 documents citing this exemption.
Example documents
7(1)(d)(iv)Would disclose a confidential source or informant4 upheld7 rejected3 partial16 total
Would disclose a confidential source or informant
4 upheld (no violation found) · 7 rejected (violation found) · 3 partial violation · 2 closed / insufficient info / other, out of 16 documents citing this exemption.
Example documents
7(1)(d)(v)Would disclose unique investigative techniques0 upheld3 rejected3 total
Would disclose unique investigative techniques
0 upheld (no violation found) · 3 rejected (violation found), out of 3 documents citing this exemption.
Example documents
7(1)(d)(vi)Would endanger the life or safety of law enforcement or others0 upheld5 rejected5 total
Would endanger the life or safety of law enforcement or others
0 upheld (no violation found) · 5 rejected (violation found), out of 5 documents citing this exemption.
Example documents
7(1)(d)(vii)Would obstruct an ongoing criminal investigation1 upheld2 rejected3 total
Would obstruct an ongoing criminal investigation
1 upheld (no violation found) · 2 rejected (violation found), out of 3 documents citing this exemption.
Example documents
7(1)(dd)Certain Public Aid Code correspondence/appeals1 upheld0 rejected1 total
Certain Public Aid Code correspondence/appeals
1 upheld (no violation found) · 0 rejected (violation found), out of 1 documents citing this exemption.
Example documents
7(1)(e-5)Records available to an inmate through the facility library1 upheld0 rejected1 total
Records available to an inmate through the facility library
1 upheld (no violation found) · 0 rejected (violation found), out of 1 documents citing this exemption.
Example documents
7(1)(e)Correctional/detention facility security records2 upheld1 rejected4 total
Correctional/detention facility security records
2 upheld (no violation found) · 1 rejected (violation found) · 1 closed / insufficient info / other, out of 4 documents citing this exemption.
Example documents
7(1)(ee)Minors' personal info in park-district program registrations1 upheld0 rejected1 total
Minors' personal info in park-district program registrations
1 upheld (no violation found) · 0 rejected (violation found), out of 1 documents citing this exemption.
Example documents
7(1)(f)Preliminary drafts, notes, and deliberative materials12 upheld35 rejected8 partial58 total
Preliminary drafts, notes, and deliberative materials (pre-decisional "draft" exemption)
12 upheld (no violation found) · 35 rejected (violation found) · 8 partial violation · 3 closed / insufficient info / other, out of 58 documents citing this exemption.
Example documents
- Email attachments between school board members
- Records identifying officers flagged under Brady/Giglio protocols
- Policies and reports on police shootings and in-custody deaths
- A letter requesting a vote of no confidence
- Employee survey responses for performance evaluations
- An outgoing police chief's email to staff on policies
7(1)(ff)Personal info in park-district programs aimed at minors1 upheld0 rejected1 total
Personal info in park-district programs aimed at minors
1 upheld (no violation found) · 0 rejected (violation found), out of 1 documents citing this exemption.
Example documents
7(1)(g)Trade secrets and confidential commercial/financial information2 upheld11 rejected15 total
Trade secrets and confidential commercial/financial information
2 upheld (no violation found) · 11 rejected (violation found) · 2 closed / insufficient info / other, out of 15 documents citing this exemption.
Example documents
- A non-disclosure agreement for a commercial development project
- Aggregate inmate head injury data and evaluation policies
- Manganese throughput reports submitted to a public health department
- Developer cost records for a city-funded redevelopment project
- A contract amendment with a capitation rate
- Financial terms of wastewater facility contracts and invoices
7(1)(h)Bids and proposals, until a contract is awarded2 upheld0 rejected3 total
Bids and proposals, until a contract is awarded
2 upheld (no violation found) · 0 rejected (violation found) · 1 closed / insufficient info / other, out of 3 documents citing this exemption.
Example documents
7(1)(i)Valuable formulae, designs, and research data1 upheld1 rejected2 total
Valuable formulae, designs, and research data
1 upheld (no violation found) · 1 rejected (violation found), out of 2 documents citing this exemption.
Example documents
7(1)(j)Educational testing/evaluation records0 upheld1 rejected1 total
Educational testing/evaluation records (general)
0 upheld (no violation found) · 1 rejected (violation found), out of 1 documents citing this exemption.
Example documents
7(1)(j)(ii)Peer evaluation of faculty0 upheld0 rejected1 partial3 total
Peer evaluation of faculty
0 upheld (no violation found) · 0 rejected (violation found) · 1 partial violation · 2 closed / insufficient info / other, out of 3 documents citing this exemption.
Example documents
7(1)(j)(iv)Faculty course/research materials2 upheld1 rejected1 partial6 total
Faculty course/research materials
2 upheld (no violation found) · 1 rejected (violation found) · 1 partial violation · 2 closed / insufficient info / other, out of 6 documents citing this exemption.
Example documents
- Animal research protocol and medical records
- Training materials for the Illinois Health Insurance Marketplace
- An internal investigation into a professor's research and IRB process
- Curriculum materials on gender and sexuality education from a third-party vendor
- A university lecture recording used in a course
- Police training curriculum and lesson plans
7(1)(k)Architectural/engineering security-sensitive construction documents5 upheld0 rejected6 total
Architectural/engineering security-sensitive construction documents
5 upheld (no violation found) · 0 rejected (violation found) · 1 closed / insufficient info / other, out of 6 documents citing this exemption.
Example documents
- Construction documents for a solar facility permit
- A comprehensive index of binding Public Access Counselor opinions issued from 2010 to 2026
- Engineering plans for water reclamation facilities
- Blueprints for condominium units
- Building permits and inspection records for commercial structures
- Maps of residential water shutoff valve locations
7(1)(kk)Public body's own financial account/security credentials2 upheld0 rejected1 partial3 total
Public body's own financial account/security credentials
2 upheld (no violation found) · 0 rejected (violation found) · 1 partial violation, out of 3 documents citing this exemption.
Example documents
7(1)(l)Closed-session meeting minutes not yet released under OMA Sec. 2.060 upheld1 rejected3 total
Closed-session meeting minutes not yet released under OMA Sec. 2.06
0 upheld (no violation found) · 1 rejected (violation found) · 2 closed / insufficient info / other, out of 3 documents citing this exemption.
Example documents
7(1)(ll)School district threat-assessment team records1 upheld0 rejected1 total
School district threat-assessment team records
1 upheld (no violation found) · 0 rejected (violation found), out of 1 documents citing this exemption.
Example documents
7(1)(m)Attorney/auditor communications and litigation-preparation materials5 upheld19 rejected6 partial31 total
Attorney/auditor communications and litigation-preparation materials (attorney-client-style privilege)
5 upheld (no violation found) · 19 rejected (violation found) · 6 partial violation · 1 closed / insufficient info / other, out of 31 documents citing this exemption.
Example documents
- Records of a payment to an alderman and a settlement agreement
- Email attachments between school board members
- Records identifying officers flagged under Brady/Giglio protocols
- A letter requesting a vote of no confidence
- Reports to county board on official's degree-fund use
- Essential employee designation records
7(1)(n)Employee grievance/discipline adjudication records1 upheld9 rejected1 partial11 total
Employee grievance/discipline adjudication records (except final discipline outcomes)
1 upheld (no violation found) · 9 rejected (violation found) · 1 partial violation, out of 11 documents citing this exemption.
Example documents
- Police video of a former deputy chief's DUI arrest
- A mayor's termination letter to a village clerk
- Video surveillance footage from an animal control facility
- A letter requesting a vote of no confidence
- Misconduct complaints against a former district police officer
- Employment, termination, and reinstatement records for a university employee
7(1)(o)Data-processing/IT security information1 upheld0 rejected2 partial4 total
Data-processing/IT security information
1 upheld (no violation found) · 0 rejected (violation found) · 2 partial violation · 1 closed / insufficient info / other, out of 4 documents citing this exemption.
Example documents
7(1)(p)Collective bargaining negotiation records1 upheld1 rejected1 partial3 total
Collective bargaining negotiation records (final contracts stay public)
1 upheld (no violation found) · 1 rejected (violation found) · 1 partial violation, out of 3 documents citing this exemption.
Example documents
7(1)(q)Licensing/employment exam questions and scoring keys2 upheld0 rejected1 partial5 total
Licensing/employment exam questions and scoring keys
2 upheld (no violation found) · 0 rejected (violation found) · 1 partial violation · 2 closed / insufficient info / other, out of 5 documents citing this exemption.
Example documents
7(1)(r)Real estate purchase negotiation records, until completed1 upheld1 rejected2 total
Real estate purchase negotiation records, until completed
1 upheld (no violation found) · 1 rejected (violation found), out of 2 documents citing this exemption.
Example documents
7(1)(s)Intergovernmental risk-management/self-insurance pool records2 upheld2 rejected4 total
Intergovernmental risk-management/self-insurance pool records
2 upheld (no violation found) · 2 rejected (violation found), out of 4 documents citing this exemption.
Example documents
7(1)(t)Financial institution/insurer regulatory examination reports2 upheld2 rejected4 total
Financial institution/insurer regulatory examination reports
2 upheld (no violation found) · 2 rejected (violation found), out of 4 documents citing this exemption.
Example documents
7(1)(u)Electronic-signature security codes/keys0 upheld1 rejected1 total
Electronic-signature security codes/keys
0 upheld (no violation found) · 1 rejected (violation found), out of 1 documents citing this exemption.
Example documents
7(1)(v)Security vulnerability assessments and response plans3 upheld6 rejected1 partial12 total
Security vulnerability assessments and response plans
3 upheld (no violation found) · 6 rejected (violation found) · 1 partial violation · 2 closed / insufficient info / other, out of 12 documents citing this exemption.
Example documents
- Excel file of scattered-site unit addresses and occupancy status
- 911 call response time data from an emergency management office
- A comprehensive index of binding Public Access Counselor opinions issued from 2010 to 2026
- Number of sworn officers per police district
- Jail inspection reports and security-round logs
- Police use-of-force reports for 2017
7(1)(x)Utility facility location/security maps3 upheld0 rejected3 total
Utility facility location/security maps
3 upheld (no violation found) · 0 rejected (violation found), out of 3 documents citing this exemption.
Example documents
OMA exceptions — 5 ILCS 120/2(c)
5 ILCS 120/2(a)Openness required0 upheld0 rejected1 partial1 total
Openness required (the basic open-meetings mandate, subject to the Sec. 2(c) exceptions)
0 upheld (no violation found) · 0 rejected (violation found) · 1 partial violation, out of 1 documents citing this exception.
Example documents
5 ILCS 120/2(c)General closed-session exceptions0 upheld14 rejected2 partial16 total
General closed-session exceptions (cites Sec. 2(c) as a whole without naming a specific numbered exception)
0 upheld (no violation found) · 14 rejected (violation found) · 2 partial violation, out of 16 documents citing this exception.
Example documents
- A village board's closed-session discussion of overdue loans
- Closed-session discussion of a book's removal from curriculum
- Closed-session discussion of a principal evaluation process
- A board's closed-session discussion of property sale or lease
- Closed-session discussion of a police services contract
- A finance committee's closed meeting on a hiring freeze
5 ILCS 120/2(c)(1)Employee/contractor appointment, discipline, or performance1 upheld16 rejected5 partial22 total
Employee/contractor appointment, discipline, or performance
1 upheld (no violation found) · 16 rejected (violation found) · 5 partial violation, out of 22 documents citing this exception.
Example documents
- Closed-session discussion of transportation contract bids
- A finance committee's closed-session discussion of elected officials' duties and salaries
- Closed-session discussion of employee pay raises
- Closed-session discussion of municipal budgetary matters
- Closed-session discussion of an advisory opinion
- Closed-session discussion of a volunteer's performance and FOIA strategy
5 ILCS 120/2(c)(2)Collective negotiating matters / salary schedules1 upheld1 rejected2 partial4 total
Collective negotiating matters / salary schedules
1 upheld (no violation found) · 1 rejected (violation found) · 2 partial violation, out of 4 documents citing this exception.
Example documents
5 ILCS 120/2(c)(3)Filling a public office / removing an office-holder0 upheld2 rejected2 total
Filling a public office / removing an office-holder
0 upheld (no violation found) · 2 rejected (violation found), out of 2 documents citing this exception.
Example documents
5 ILCS 120/2(c)(4)Evidence to a quasi-adjudicative body1 upheld3 rejected4 total
Evidence to a quasi-adjudicative body
1 upheld (no violation found) · 3 rejected (violation found), out of 4 documents citing this exception.
Example documents
5 ILCS 120/2(c)(5)Purchase or lease of real property1 upheld4 rejected5 total
Purchase or lease of real property
1 upheld (no violation found) · 4 rejected (violation found), out of 5 documents citing this exception.
Example documents
5 ILCS 120/2(c)(6)Setting a sale/lease price for public body's own property1 upheld4 rejected5 total
Setting a sale/lease price for public body's own property
1 upheld (no violation found) · 4 rejected (violation found), out of 5 documents citing this exception.
Example documents
5 ILCS 120/2(c)(9)Student disciplinary cases0 upheld1 rejected1 total
Student disciplinary cases
0 upheld (no violation found) · 1 rejected (violation found), out of 1 documents citing this exception.
Example documents
5 ILCS 120/2(c)(10)Placement of individual students in special education0 upheld1 rejected1 partial2 total
Placement of individual students in special education
0 upheld (no violation found) · 1 rejected (violation found) · 1 partial violation, out of 2 documents citing this exception.
Example documents
5 ILCS 120/2(c)(11)Pending, probable, or imminent litigation3 upheld9 rejected4 partial18 total
Pending, probable, or imminent litigation
3 upheld (no violation found) · 9 rejected (violation found) · 4 partial violation · 2 closed / insufficient info / other, out of 18 documents citing this exception.
Example documents
- Closed-session discussion of sewer main issues
- A city council's closed-session discussion of a revenue-sharing agreement
- Closed-session discussion of possible litigation
- Closed-session discussion of litigation without recording basis
- Unrecorded closed-session landfill ordinance discussion
- A village council's review of closed-session minutes
5 ILCS 120/2(c)(15)Professional ethics/performance review by a licensing advisory body1 upheld0 rejected1 total
Professional ethics/performance review by a licensing advisory body
1 upheld (no violation found) · 0 rejected (violation found), out of 1 documents citing this exception.
Example documents
5 ILCS 120/2(c)(16)Self-evaluation with a statewide/regional association2 upheld0 rejected2 total
Self-evaluation with a statewide/regional association
2 upheld (no violation found) · 0 rejected (violation found), out of 2 documents citing this exception.
Example documents
5 ILCS 120/2(c)(21)Reviewing minutes of a lawfully closed meeting0 upheld1 rejected2 total
Reviewing minutes of a lawfully closed meeting
0 upheld (no violation found) · 1 rejected (violation found) · 1 closed / insufficient info / other, out of 2 documents citing this exception.
Example documents
5 ILCS 120/2(e)Final action ban in closed session0 upheld0 rejected1 partial1 total
Final action ban in closed session (no final action may be taken at a closed meeting)
0 upheld (no violation found) · 0 rejected (violation found) · 1 partial violation, out of 1 documents citing this exception.