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  <title>Illinois FOIA &amp; OMA Reference: 5 ILCS 120/2(c)(1)</title>
  <link href="https://illinoisfoia.org/exemptions/5-ilcs-120-2-c-1/feed.xml" rel="self"/>
  <link href="https://illinoisfoia.org/exemptions/5-ilcs-120-2-c-1/"/>
  <id>https://illinoisfoia.org/exemptions/5-ilcs-120-2-c-1/</id>
  <updated>2026-01-02T00:00:00Z</updated>
  <entry>
    <title>Chicago Board of Ethics violated OMA by discussing advisory opinion in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-84086/"/>
    <id>https://illinoisfoia.org/opinions/letter-84086/</id>
    <updated>2026-01-02T00:00:00Z</updated>
    <summary>A citizen complained that the Chicago Board of Ethics held a private meeting to discuss a specific advisory opinion, which the citizen believed should have been public. The Attorney General's office reviewed the meeting records and agreed that the Board broke the law by keeping that discussion private. The Board has been asked to release the minutes and recording of that specific portion of the meeting.</summary>
  </entry>
  <entry>
    <title>Chicago Board of Ethics violated OMA by discussing policy matters in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-72604/"/>
    <id>https://illinoisfoia.org/opinions/letter-72604/</id>
    <updated>2024-09-18T00:00:00Z</updated>
    <summary>A citizen complained that the Chicago Board of Ethics discussed policy issues in a private meeting that should have been held in public. The Attorney General's office reviewed the meeting recording and agreed that the Board improperly discussed these topics behind closed doors. The Board has been asked to release the portions of the meeting minutes and recordings related to those specific discussions.</summary>
  </entry>
  <entry>
    <title>Joliet Junior College Board of Trustees violated Open Meetings Act by voting on censure motions not on agenda</title>
    <link href="https://illinoisfoia.org/opinions/letter-81010/"/>
    <id>https://illinoisfoia.org/opinions/letter-81010/</id>
    <updated>2024-07-16T00:00:00Z</updated>
    <summary>A college board held a closed-door meeting to discuss a trustee's conduct and subsequently voted on thirteen motions to censure her. The Attorney General's office found that the board failed to follow the law because they did not list these censure votes on the public meeting agenda beforehand. This means the board denied the public the required notice of the actions they intended to take.</summary>
  </entry>
  <entry>
    <title>Village of Bartonville violated Open Meetings Act by refusing to provide closed session recording</title>
    <link href="https://illinoisfoia.org/opinions/letter-71217/"/>
    <id>https://illinoisfoia.org/opinions/letter-71217/</id>
    <updated>2024-01-12T00:00:00Z</updated>
    <summary>A reporter alleged that a Village Board improperly discussed a volunteer firefighter and a FOIA response in closed session. The Illinois Attorney General's Public Access Counselor found that the Board violated the Open Meetings Act by refusing to provide the closed session recording and unredacted minutes for confidential review, as required by law. The determination did not reach a final conclusion on whether the closed session discussion itself was improper.</summary>
  </entry>
  <entry>
    <title>Chicago Board of Ethics violated OMA by discussing query report in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-74629/"/>
    <id>https://illinoisfoia.org/opinions/letter-74629/</id>
    <updated>2023-08-10T00:00:00Z</updated>
    <summary>A citizen complained that the Chicago Board of Ethics held a private meeting to discuss a report that should have been discussed in public. The Attorney General's office reviewed the meeting recording and found that the Board did not have a legal reason to keep that specific discussion private. This means the Board failed to follow the transparency requirements of the Open Meetings Act.</summary>
  </entry>
  <entry>
    <title>Discussion in Closed Session oft he Appointment, Employment, Compensation, or Performance of Specific Employees Failure to Cite an Applicable Exception Before Closing a Meeting to the Public; Improper Closed Session Discussion of Bids for a Student Transportation Contract</title>
    <link href="https://illinoisfoia.org/opinions/2022-pac-71177/"/>
    <id>https://illinoisfoia.org/opinions/2022-pac-71177/</id>
    <updated>2022-07-12T00:00:00Z</updated>
    <summary>The requester, a newspaper publisher, challenged three closed sessions held during a single school board meeting, alleging that discussion of the bidding process for the district's student transportation contract exceeded the scope of any Open Meetings Act exception. The Public Access Counselor held that the board properly discussed personnel matters during two of the sessions, but that its discussion of the transportation-bid dispute in the third session was not shown to involve probable or imm</summary>
  </entry>
  <entry>
    <title>Brookfield LaGrange Park School Dist. 95 Board did not violate OMA in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-69573/"/>
    <id>https://illinoisfoia.org/opinions/letter-69573/</id>
    <updated>2022-05-12T00:00:00Z</updated>
    <summary>A citizen complained that a local school board discussed improper topics during a private, closed-door meeting. After reviewing the matter, the Illinois Attorney General's office found that the board stayed within the legal rules for closed sessions. As a result, the case is closed with no finding of a violation.</summary>
  </entry>
  <entry>
    <title>Lincoln Elementary SD 156 Board violated OMA by voting on unagendized committee formation</title>
    <link href="https://illinoisfoia.org/opinions/letter-58721/"/>
    <id>https://illinoisfoia.org/opinions/letter-58721/</id>
    <updated>2019-08-12T00:00:00Z</updated>
    <summary>A school board member complained that the Board voted on forming two committees at its May 3, 2019 meeting, even though that item was not listed on the public agenda. The Illinois Attorney General's Public Access Bureau found that the Board violated the Open Meetings Act by taking final action on an item not identified on the agenda for that regular meeting. The Bureau also found that the Board did not violate the Act regarding a closed session discussion at its May 20, 2019 special meeting, but</summary>
  </entry>
  <entry>
    <title>Village of Sauk Village Board violated OMA by failing to cite closed session exception</title>
    <link href="https://illinoisfoia.org/opinions/letter-58515/"/>
    <id>https://illinoisfoia.org/opinions/letter-58515/</id>
    <updated>2019-07-12T00:00:00Z</updated>
    <summary>A citizen complained that the Village of Sauk Village Board of Trustees did not properly announce why they were going into a private, closed-door meeting. The Attorney General's office agreed, finding that the Board failed to follow the law requiring them to publicly state the specific legal reason for closing the meeting. While the Board cannot undo the past meeting, they were asked to properly cite the law for any future closed sessions.</summary>
  </entry>
  <entry>
    <title>Elmhurst Park District Board discussed topics outside closed session exception, violating OMA</title>
    <link href="https://illinoisfoia.org/opinions/letter-54122/"/>
    <id>https://illinoisfoia.org/opinions/letter-54122/</id>
    <updated>2019-05-31T00:00:00Z</updated>
    <summary>A citizen complained that the Elmhurst Park District Board of Commissioners improperly closed a portion of its October 10, 2017, meeting to discuss a succession plan for the executive director, and may have taken final action on that plan in closed session. The Illinois Attorney General's Public Access Bureau found that the Board did not take final action in closed session, but did discuss certain topics that were outside the scope of the legal exception it used to close the meeting, violating t</summary>
  </entry>
  <entry>
    <title>Village of Lisbon Board violated OMA for improper closed session procedures and discussion</title>
    <link href="https://illinoisfoia.org/opinions/letter-56288/"/>
    <id>https://illinoisfoia.org/opinions/letter-56288/</id>
    <updated>2019-05-06T00:00:00Z</updated>
    <summary>A citizen complained that the Village of Lisbon Board of Trustees held an improper closed-door meeting. The Attorney General's office found that the Board did not follow the correct legal steps to enter the closed session and discussed a topic that should have been handled in public. While the Board did not violate the law regarding final actions taken in that meeting, the overall process for entering and conducting the closed session was legally deficient.</summary>
  </entry>
  <entry>
    <title>Waukegan School Board violated OMA by discussing board conduct in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-57245/"/>
    <id>https://illinoisfoia.org/opinions/letter-57245/</id>
    <updated>2019-04-29T00:00:00Z</updated>
    <summary>A reporter alleged that a school board improperly discussed topics in a private meeting that should have been held in public. The Attorney General's office agreed, finding that the board discussed issues not covered by the legal exceptions they claimed. The board was asked to release the audio recording of those specific parts of the meeting to the public.</summary>
  </entry>
  <entry>
    <title>Westmont School Board violated OMA by discussing general staffing strategy in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-21622/"/>
    <id>https://illinoisfoia.org/opinions/letter-21622/</id>
    <updated>2018-11-09T00:00:00Z</updated>
    <summary>A citizen complained that a school board discussed staffing and retirement issues behind closed doors. The Attorney General's office found that the board broke the law because they discussed general staffing plans, which must be done in public, rather than specific personnel matters. No further action was required because the board had already received training on the issue.</summary>
  </entry>
  <entry>
    <title>Discussion of the Duties and Salaries of Elected Officials in Closed Session</title>
    <link href="https://illinoisfoia.org/opinions/2018-pac-54229/"/>
    <id>https://illinoisfoia.org/opinions/2018-pac-54229/</id>
    <updated>2018-10-30T00:00:00Z</updated>
    <summary>The requester, an elected county auditor, sought review after a county board committee entered closed session, citing the exception for discussing specific employees, to discuss the salaries and duties of independently elected county officials including herself. The Public Access Counselor held that elected officials such as a county auditor or coroner are not &quot;employees&quot; of the county for purposes of the specific-employees exception, since the county does not direct their work or have authority</summary>
  </entry>
  <entry>
    <title>Beasley Academic Center LSC violated OMA by not posting agenda 48 hours in advance</title>
    <link href="https://illinoisfoia.org/opinions/letter-52881/"/>
    <id>https://illinoisfoia.org/opinions/letter-52881/</id>
    <updated>2018-07-06T00:00:00Z</updated>
    <summary>A member of the Beasley Academic Center Local School Council complained that the Council failed to post the agenda for its April 2, 2018, special meeting 48 hours in advance, and also raised issues about adding an agenda item and voting in closed session during its April 10, 2018, meeting. The Illinois Attorney General's Public Access Bureau found that the Council violated the Open Meetings Act by not continuously posting the agenda for the April 2 meeting, but because the general subject matter</summary>
  </entry>
  <entry>
    <title>Norridge School Board violated OMA by discussing committee appointments in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-52158/"/>
    <id>https://illinoisfoia.org/opinions/letter-52158/</id>
    <updated>2018-06-14T00:00:00Z</updated>
    <summary>A school board member complained that their board held a private meeting to discuss appointing members to a negotiations committee. The Attorney General's office reviewed the recording and found that this topic was not allowed to be discussed in private under the Open Meetings Act. This means the board should have held that specific discussion in an open, public meeting.</summary>
  </entry>
  <entry>
    <title>Pekin City Council violated OMA by discussing bidding process in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-51599/"/>
    <id>https://illinoisfoia.org/opinions/letter-51599/</id>
    <updated>2018-03-28T00:00:00Z</updated>
    <summary>A citizen complained that the Pekin City Council discussed bidding processes in a closed session, which should have been public. The Public Access Bureau of the Illinois Attorney General's Office reviewed the matter and concluded that the Council violated the Open Meetings Act by discussing matters in closed session that were outside the scope of the exception they cited. This means the Council failed to follow the law's requirement that public business be conducted openly.</summary>
  </entry>
  <entry>
    <title>City of Sandwich City Council improperly terminated employee during closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-49854/"/>
    <id>https://illinoisfoia.org/opinions/letter-49854/</id>
    <updated>2017-11-28T00:00:00Z</updated>
    <summary>A news reporter alleged that the City of Sandwich City Council improperly terminated an employee during a closed session. The Illinois Attorney General's Public Access Bureau determined that the Council improperly took final action when it approved terminating an employee in closed session without first voting in open session after providing an adequate public recital of the matter. The Bureau also found that the Council's closed session discussions on four dates did not exceed the scope of the </summary>
  </entry>
  <entry>
    <title>Parkland College Board violated OMA by failing to provide 48 hours' notice for non-emergency meeting</title>
    <link href="https://illinoisfoia.org/opinions/letter-47429/"/>
    <id>https://illinoisfoia.org/opinions/letter-47429/</id>
    <updated>2017-07-14T00:00:00Z</updated>
    <summary>Parkland College held an 'emergency' meeting without giving the public the required 48 hours' notice. The Attorney General's office found that the situation did not qualify as a true emergency, meaning the college broke the law by not providing proper notice. However, the office also ruled that the topics discussed during the meeting's private session were legally allowed to be discussed behind closed doors.</summary>
  </entry>
  <entry>
    <title>Improper Discussion of Salary Increases for City Employees in a Closed Meeting</title>
    <link href="https://illinoisfoia.org/opinions/2016-pac-44249/"/>
    <id>https://illinoisfoia.org/opinions/2016-pac-44249/</id>
    <updated>2016-12-23T00:00:00Z</updated>
    <summary>The requester, a newspaper publisher, alleged that a city council closed part of a meeting to discuss and then approved an across-the-board cost-of-living raise for city employees under the exception for discussing specific employees. The Public Access Counselor held that the specific-employees exception does not extend to a general budgetary discussion affecting a broad category of employees, and that a second exception the city council later invoked for salary schedules could not be relied on </summary>
  </entry>
  <entry>
    <title>Kankakee School District 111 Board violated Open Meetings Act by restricting public comment and failing to explain closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-44262/"/>
    <id>https://illinoisfoia.org/opinions/letter-44262/</id>
    <updated>2016-12-12T00:00:00Z</updated>
    <summary>A citizen complained that a school board cut off his public comments and failed to explain why they were going into a private closed-door meeting. The Attorney General's office agreed, finding that the board violated the Open Meetings Act by enforcing a restriction on public comment that was not among its established and recorded rules, and by not adequately informing the public of the reason for entering a second closed session. The determination did not address whether the closed session itsel</summary>
  </entry>
  <entry>
    <title>Improper Discussion in Closed Session of Budgetary Matters</title>
    <link href="https://illinoisfoia.org/opinions/2012-pac-19265/"/>
    <id>https://illinoisfoia.org/opinions/2012-pac-19265/</id>
    <updated>2012-07-11T00:00:00Z</updated>
    <summary>The requester, a journalist, challenged a village government's practice of discussing its budget during personnel- and finance-committee sessions closed to the public under the Open Meetings Act's employee-related exception. The Public Access Counselor found that while some closed-session discussion of individual employees was proper, significant portions instead addressed general budgetary and staffing issues that fall outside that narrow exception and must be conducted in open session. The vil</summary>
  </entry>
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