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  <title>Illinois FOIA &amp; OMA Reference: 5 ILCS 120/2(c)</title>
  <link href="https://illinoisfoia.org/exemptions/5-ilcs-120-2-c/feed.xml" rel="self"/>
  <link href="https://illinoisfoia.org/exemptions/5-ilcs-120-2-c/"/>
  <id>https://illinoisfoia.org/exemptions/5-ilcs-120-2-c/</id>
  <updated>2026-04-17T00:00:00Z</updated>
  <entry>
    <title>Improper Closed Session Discussion of Overdue Loans</title>
    <link href="https://illinoisfoia.org/opinions/2026-pac-91898/"/>
    <id>https://illinoisfoia.org/opinions/2026-pac-91898/</id>
    <updated>2026-04-17T00:00:00Z</updated>
    <summary>The requester, a village trustee, alleged that a village board's mayor cited a &quot;personnel&quot; closed-session exception but then discussed businesses' overdue tax-increment-financing loans instead. The Public Access Counselor held that the board violated the Open Meetings Act's procedure for entering closed session by failing to publicly cite and record the actual exception relied upon, and that the loan discussion was not shown to involve probable or imminent litigation as later claimed. The board </summary>
  </entry>
  <entry>
    <title>Oak Brook Park District violated OMA by discussing vacancies and discipline in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-88005/"/>
    <id>https://illinoisfoia.org/opinions/letter-88005/</id>
    <updated>2025-11-26T00:00:00Z</updated>
    <summary>A citizen complained that the Oak Brook Park District held a private meeting that should have been open to the public. The Attorney General's office agreed that the meeting was improperly closed. However, because the District already released the records of that meeting to the public, the case is now closed with no further action required.</summary>
  </entry>
  <entry>
    <title>Indian Creek School Board violated OMA by vague vote on staff raises</title>
    <link href="https://illinoisfoia.org/opinions/letter-86632/"/>
    <id>https://illinoisfoia.org/opinions/letter-86632/</id>
    <updated>2025-08-06T00:00:00Z</updated>
    <summary>A citizen complained that a school board violated the Open Meetings Act by not providing enough detail in its public vote on non-certified staff raises and by discussing across-the-board pay raises and a construction bid in closed session. The Attorney General's office found that the board violated the public recital requirement of section 2(e) because its description of 'non-certified staff' was too vague to inform the public which employees were affected. Regarding the closed-session allegatio</summary>
  </entry>
  <entry>
    <title>Improper Closed Session Discussion of Removing Book from Curriculum</title>
    <link href="https://illinoisfoia.org/opinions/2023-pac-78356/"/>
    <id>https://illinoisfoia.org/opinions/2023-pac-78356/</id>
    <updated>2023-12-27T00:00:00Z</updated>
    <summary>The requester, a resident, alleged that a school board improperly discussed removing a book from an English class curriculum in closed session after a parent's grievance about the book reached the board. The Public Access Counselor held that none of the personnel, quasi-adjudicative, or student-placement exceptions the board cited authorized closing the meeting, because the board was actually deliberating on a curriculum decision affecting students generally rather than a specific employee's con</summary>
  </entry>
  <entry>
    <title>Cook County Board of Ethics violated OMA by discussing audits in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-75164/"/>
    <id>https://illinoisfoia.org/opinions/letter-75164/</id>
    <updated>2023-10-03T00:00:00Z</updated>
    <summary>A citizen complained that the Cook County Board of Ethics held closed-door meetings to discuss topics that should have been open to the public. The Attorney General's office investigated and agreed, finding that the Board discussed audit and rule-change matters that did not qualify for a closed session. The Board was asked to release the minutes and recordings of those specific discussions to the public.</summary>
  </entry>
  <entry>
    <title>Dunlap School Board violated OMA by discussing book removal policy in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-71523/"/>
    <id>https://illinoisfoia.org/opinions/letter-71523/</id>
    <updated>2023-03-24T00:00:00Z</updated>
    <summary>A citizen complained that a school board improperly discussed removing a book from a curriculum during a closed session. The Attorney General's office found that the board discussed topics beyond the allowed exception (personnel matters) and implemented a policy change without taking final action in an open meeting, violating the Open Meetings Act. The office requested the board make part of its closed session minutes public and cautioned it to follow the law in the future, but did not declare t</summary>
  </entry>
  <entry>
    <title>City of Oglesby Council violated OMA by discussing budget in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-63411/"/>
    <id>https://illinoisfoia.org/opinions/letter-63411/</id>
    <updated>2022-11-18T00:00:00Z</updated>
    <summary>A citizen complained that the Oglesby City Council held a private meeting to discuss public budget issues like water rates and taxes, which should have been discussed in public. The Attorney General's office agreed, finding that the Council mixed allowed private personnel discussions with forbidden public budget talk. The PAC requested that the City release the recording of the meeting to the public, with only the sensitive personnel information redacted.</summary>
  </entry>
  <entry>
    <title>Prairie Hill School Board committees failed to post agendas and minutes for committee meetings</title>
    <link href="https://illinoisfoia.org/opinions/letter-72129/"/>
    <id>https://illinoisfoia.org/opinions/letter-72129/</id>
    <updated>2022-04-14T00:00:00Z</updated>
    <summary>A complainant alleged multiple Open Meetings Act violations by a school board and its committees, including improper closed sessions and failures to post committee agendas and minutes. The PAC found most of the closed-session timing allegations untimely, but did find that the board's committees violated OMA by not preparing or posting required agendas and minutes, that the board's generic &quot;personnel&quot; citation for one closed session inadequately identified the specific statutory exception, and th</summary>
  </entry>
  <entry>
    <title>South Loop Elementary School Local School Council violated OMA by discussing principal evaluation in closed session</title>
    <link href="https://illinoisfoia.org/opinions/2020-pac-62037/"/>
    <id>https://illinoisfoia.org/opinions/2020-pac-62037/</id>
    <updated>2020-06-02T00:00:00Z</updated>
    <summary>The requester, a member of a school's local school council, sought review after the council entered closed session, citing the exception for discussing specific employees, to discuss the general process and timeline for evaluating the school's principal rather than the principal's individual performance. The Public Access Counselor held that the closed-session exception for specific employees does not extend to general discussions of evaluation procedures applicable to a category of employees, s</summary>
  </entry>
  <entry>
    <title>Aurora Library Board violated OMA by discussing branch relocation in closed session</title>
    <link href="https://illinoisfoia.org/opinions/letter-55687/"/>
    <id>https://illinoisfoia.org/opinions/letter-55687/</id>
    <updated>2019-04-02T00:00:00Z</updated>
    <summary>A citizen complained that the Aurora Public Library Board discussed moving a library branch behind closed doors, which is generally not allowed under the Open Meetings Act. The Attorney General's office reviewed the recordings and found that most of the closed session discussions were legal, but discrete portions of the discussions were not authorized by the exceptions the Board cited. The determination does not order the Board to release any recordings or take any other action.</summary>
  </entry>
  <entry>
    <title>City of Peru Committee of Whole violated OMA by unauthorized closed session discussions</title>
    <link href="https://illinoisfoia.org/opinions/letter-51987/"/>
    <id>https://illinoisfoia.org/opinions/letter-51987/</id>
    <updated>2018-04-18T00:00:00Z</updated>
    <summary>A citizen complained that the City of Peru's Committee of the Whole held closed sessions to discuss merging police departments, which is not allowed under the Open Meetings Act. The Illinois Attorney General's Public Access Bureau concluded that the committee held unauthorized closed session discussions during four meetings in 2017 and 2018, and that the closed session minutes for those meetings did not contain sufficient information about the matters discussed.</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>Failure to Cite an Applicable Exception Before Closing a Meeting to the Public; Improper Discussion ofa Hiring Freeze in a Closed Meeting</title>
    <link href="https://illinoisfoia.org/opinions/2015-pac-35861/"/>
    <id>https://illinoisfoia.org/opinions/2015-pac-35861/</id>
    <updated>2015-09-16T00:00:00Z</updated>
    <summary>The requester challenged a county board's finance committee for closing part of a meeting to discuss a hiring freeze and the elimination of an employee's position after citing only &quot;personnel&quot; as its reason. The Public Access Counselor held that a bare reference to &quot;personnel&quot; does not adequately disclose which Open Meetings Act exception authorizes a closed session, that discussing how eliminating a position would affect a specific employee fell within the personnel exception but that the broad</summary>
  </entry>
  <entry>
    <title>Failure to Cite Closed Session Exception; Improper Discussion of Proposed Police Services Contract in Closed Session; Taking Final Action on Matter Not on Meeting Agenda</title>
    <link href="https://illinoisfoia.org/opinions/2015-pac-35119/"/>
    <id>https://illinoisfoia.org/opinions/2015-pac-35119/</id>
    <updated>2015-08-04T00:00:00Z</updated>
    <summary>The requester alleged that a village government's board voted in closed session to disband its police department and enter into a new policing contract without properly noticing the topic. The Public Access Counselor found that the board failed to publicly cite and record the specific Open Meetings Act exception authorizing its closed session, that the closed-session discussion of a proposed police-services contract exceeded the narrow personnel exception it later invoked (since it concerned a c</summary>
  </entry>
  <entry>
    <title>Improper Discussion of Financial Matters and Disposal of Property in a Closed Meeting</title>
    <link href="https://illinoisfoia.org/opinions/2015-pac-33652/"/>
    <id>https://illinoisfoia.org/opinions/2015-pac-33652/</id>
    <updated>2015-03-20T00:00:00Z</updated>
    <summary>A requester alleged that a community college's board improperly closed part of a special meeting to discuss the college's financial condition, tuition, and possible sale or lease of college-owned property, citing the personnel and real estate purchase/lease exceptions of the Open Meetings Act. The Public Access Bureau reviewed the closed-session recording and found the board mainly discussed general budgetary and fiscal matters, which are not covered by the personnel exception even though they m</summary>
  </entry>
  <entry>
    <title>Taking Final Action at Closed Session Prohibited; Duty to Record Closed Meetings; Summary of Discussion Required in Minutes</title>
    <link href="https://illinoisfoia.org/opinions/2013-pac-23488/"/>
    <id>https://illinoisfoia.org/opinions/2013-pac-23488/</id>
    <updated>2013-05-21T00:00:00Z</updated>
    <summary>The requester, a journalist, challenged a school district for having most of its board members sign a superintendent's separation agreement during a closed session before later ratifying it with a vote in open session. The Public Access Counselor held that while discussing the superintendent's employment in closed session was proper, signing the agreement behind closed doors was itself an improper final action, and that the subsequent open-session vote did not cure the violation because the boar</summary>
  </entry>
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