7(1)(a)

FOIA

Confidential under other federal or State law

Federal/State-law confidentiality — or public defender case files, for documents issued under the other amendment version (see Sec. 7)

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Read the full statute text on /statutes →

Jump to the 32 issues decided under this provision, with a drafting brief ↓

18 upheld (no violation found) · 23 rejected (violation found) · 6 partial violation · 10 closed / insufficient info / other, out of 57 documents.

Not legal advice, and not a per-exemption ruling — this reflects each document's overall disposition. See the FAQ disclaimer.

How the Public Access Counselor has treated 7(1)(a)

Section 7(1)(a) allows a public body to withhold information that is specifically prohibited from disclosure by federal or State law or by rules adopted under such laws. The prohibition must come from outside FOIA and must actually bar release, not merely recognize a general interest in confidentiality, privacy, or non-disclosure in other contexts.

In these decisions, the Public Access Counselor generally required public bodies to identify the specific prohibiting provision and show that it applied to the records at issue. Withholding was sustained for juvenile offender information, certain minor-related information, and genetic testing reports barred by the Genetic Information Privacy Act. Withholding was rejected where bodies relied on evidentiary or discovery rules, personnel-record laws, other cannabis-licensing confidentiality provisions, student-privacy law for directory-type or de-identified information, or a reading of juvenile or body-camera laws that did not prohibit disclosure.

At a glance: 57 documents from 2012 to 2026(18 binding opinions, 39 determination letters). Most often cited alongside: 7(1)(c) (Personal privacy) (19); 7(1)(b) (Private information) (17); 7(1)(f) (Preliminary drafts, notes, and deliberative materials) (8); 7(1)(d) (Law-enforcement/administrative-proceeding records) (4); 7.5(q) (Made confidential by the Personnel Record Review Act) (3).

Recurring issues

Whether the Juvenile Court Act prohibits disclosure of an entire police report when a minor is involved as an offender, victim, or witness, or only the juvenile-protected portions. (Police reports of an incident at a high school, A police report of a sexual assault of a minor, Investigatory records on a minor's shooting death)
Whether general privacy, personnel-record, evidentiary, or discovery rules qualify as a law that specifically prohibits disclosure. (A private attorney's letter to a city law department, A mayor's termination letter to a village clerk, Redacted narrative sections of police arrest reports)
Whether student, applicant, or licensee names and addresses are barred from disclosure by student-privacy law or by confidentiality provisions in a separate licensing statute. (Names of first-time freshmen and graduation statuses, Applications for cannabis cultivation center licenses, De-identified student test scores)
Whether the Law Enforcement Officer-Worn Body Camera Act or the Genetic Information Privacy Act prohibits disclosure of the requested recordings or reports. (Police body-camera footage of a motor vehicle accident, Police body-camera and dash-camera recordings of an in-custody death, DNA phenotype reports for an unsolved murder case)

Practical points

Identify the exact federal or State provision claimed to prohibit disclosure and explain how it applies to the specific information withheld.
When only part of a record is prohibited from disclosure, redact that portion and release the remaining non-exempt information, such as adult arrest-blotter information or de-identified data.
A conclusory citation without supporting explanation is insufficient, as the public body must prove by clear and convincing evidence that the exemption applies.

Summary drafted from the linked decisions and checked against them; read the decisions themselves before relying on it. Not legal advice.

All 57 documents citing 7(1)(a)

Issues decided under 7(1)(a)

Individual questions the Public Access Bureau decided under this provision, with the rule it applied, grouped by outcome. Extracted automatically from the letters; check each source letter.

32 issues across 29 determination letters:13 violation found · 19 no violation.

Counts are per issue, not per letter, and come from automated extraction checked against sampled letters. Determination letters are not binding precedent.

Authorities the Bureau cites most on this issue

Better Gov't Ass'n v. Zaruba, 2014 IL App (2d) 140071, ¶ 27 cited 4 times
Better Gov't Ass'n v. Blagojevich, 386 Ill. App. 3d 808, 816 (4th Dist. 2008) cited 2 times
Wisnasky-Bettorf v. Pierce, 2012 IL 111253 cited 2 times
Southern Illinoisan v. Illinois Department of Public Health, 218 Ill. 2d 390, 844 N.E.2d 1 (2006) cited 2 times
Lieber v. Board of Trustees of Southern Illinois University, 176 Ill. 2d 401, 407 (1997) cited 2 times
Bright v. Dicke, 166 Ill. 2d 204, 210 (1995) cited 2 times
Bowie v. Evanston Community Consolidated School District No. 65, 128 Ill. 2d 373 (1989) cited 2 times
Rockford Police Benevolent and Protective Ass'n, Unit No. 6 v. Morrissey cited 1 times

How to challenge a denial on this issue

AI-generated summary of the decisions listed on this page, with each point linked to the letters it comes from. Determination letters are not binding precedent and this is not legal advice. Open the letter and check the PDF before relying on any point.

When a challenge is strong

The public body withholds records claiming a specific statute prohibits disclosure, but the statute only covers a subset of the records (e.g., electronic recordings but not photo arrays, or mental health services records but not law enforcement investigatory records). The body must prove the exemption applies to each record; if the statute's scope is narrower, the denial fails.Based on: Audio and video recordings of a police photo ar… · Police reports of a 1969 death at a state hospi… · 2024 · A police report of a DUI arrest and vehicle imp…
The public body withholds entire records instead of redacting exempt portions. FOIA requires redaction and disclosure of non-exempt information; withholding entire records is improper unless all parts are exempt.Based on: An email about cannabis licensing between a dep… · A school district's settlement agreement with a… · An internal investigation into a professor's re…
The public body relies on a court order to withhold records, but the order does not cover the agency's own copies or the specific records requested. The body must prove by clear and convincing evidence that the order prohibits disclosure of those records.Based on: Police reports from a 2009 case · Communications with a judge about a wrongful de…
The public body cites a federal statute or federal FOIA exemption to withhold records. Federal FOIA does not apply to state public bodies; only a specific federal or state prohibition can justify withholding under section 7(1)(a).Based on: Death investigation records and police-federal …

When the public body usually wins

The requested records are explicitly made confidential by a specific state or federal statute, such as LEADS data, library registration records, public aid records, or genetic testing information. Section 7(1)(a) exempts information specifically prohibited from disclosure by law, and these statutes clearly apply.Based on: An applicant's background check and polygraph r… · List of adult library cardholders · Personal case file records of a state human ser…
+1 more
2026 · DNA phenotype reports for an unsolved murder ca…
The records are sealed by a valid court order that explicitly covers the records held by the public body. A court order prohibiting disclosure satisfies section 7(1)(a).Based on: Police reports from a 2009 case
The records are teacher performance evaluations under the School Code and Personnel Record Review Act. These are exempt in full and cannot be redacted.Based on: Teacher evaluation performance task results
The records are closed session verbatim recordings that the public body has not determined no longer require confidential treatment. OMA section 2.06(e) prohibits disclosure.Based on: Closed-session minutes and recordings of an inv…

Points to put in your letter

If the public body claims a state law prohibits disclosure, ask them to identify the exact statutory provision and explain how it applies to each specific record. Point out that the law may only cover certain types of records (like electronic recordings, not photo arrays).Based on: Audio and video recordings of a police photo ar… · Police reports of a 1969 death at a state hospi… · 2024 · A police report of a DUI arrest and vehicle imp…
If the public body withheld entire records, argue that they must redact only the exempt information and provide the rest. Remind them that withholding an entire record is only allowed if every part is exempt.Based on: An email about cannabis licensing between a dep… · A school district's settlement agreement with a…
If the public body cites a court order, demand that they prove the order specifically prohibits disclosure of the records they hold. An order sealing court copies does not automatically seal the agency's own copies.Based on: Police reports from a 2009 case · Communications with a judge about a wrongful de…
If the public body relies on a federal law or federal FOIA exemption, state that federal FOIA does not apply to state public bodies and that only a specific federal or state prohibition can justify withholding under section 7(1)(a).Based on: Death investigation records and police-federal …

Common mistakes

Mistakenly believing that federal FOIA exemptions can be used to compel disclosure from a state public body.Based on: Death investigation records and police-federal …
Assuming that any record related to a minor is automatically exempt under the Juvenile Court Act without checking if it concerns an investigation, arrest, or custodial detention.Based on: 2024 · A police report of a DUI arrest and vehicle imp…
Accepting a public body's claim that records are exempt under a statute without demanding that the body identify the specific provision and show how it applies.Based on: Audio and video recordings of a police photo ar… · Police reports of a 1969 death at a state hospi…
Failing to argue that the public body must redact and disclose non-exempt portions when they withhold entire records.Based on: An email about cannabis licensing between a dep…

Facts to gather first

Whether the requested record is an electronic recording or a different type of document (e.g., photo array, lineup report).
Whether a court order specifically names the agency's records or only court copies.
Whether the record relates to a minor's investigation, arrest, or custodial detention, or merely mentions a minor.
Whether the record is a notice to remedy or a periodic performance evaluation.
Whether the public body has redacted or withheld entire records.

These notes are based on non-binding determination letters from the Public Access Bureau; outcomes depend on specific facts and the public body's evidence. Always verify the current version of the cited statutes and the PDF of the decision.

Drafting brief for an AI assistant

Copy this into your assistant to help draft a request, appeal, or challenge to a denial that turns on this issue. It carries the rules and decisions, not your facts: add those yourself. Machine-readable version: foia-7-1-a.json.

TOPIC: 5 ILCS 140/7(1)(a) - Confidential under other federal or State law
SOURCE: Illinois Attorney General Public Access Bureau decisions compiled at https://illinoisfoia.org/exemptions/7-1-a/
NOTE: Determination letters are not binding precedent; they show how the Bureau applies the law. Verify every decision against the source PDF before citing it.

VIOLATION FOUND (13):
- Redaction under section 7(1)(a) and JCA
  Rule: The JCA restricts juvenile law enforcement records, but the report did not concern a minor's investigation, arrest, or custodial detention, so the exemption did not apply.
  Decision: A police report of a DUI arrest and vehicle impoundment (non-binding determination letter, August 21, 2024) https://illinoisfoia.org/opinions/letter-82136/
- ISP improperly withheld documents under MHDDCA confidentiality
  Rule: MHDDCA confidentiality applies only to records and communications made in the course of providing mental health services, not to law enforcement investigatory records merely because they pertain to a named resident.
  Decision: Police reports of a 1969 death at a state hospital (non-binding determination letter, September 8, 2025) https://illinoisfoia.org/opinions/letter-84839/
- Withholding records not covered by sealing order
  Rule: A public body must demonstrate by clear and convincing evidence that withheld records are covered by a court order sealing them; otherwise, the denial is improper.
  Decision: Police reports from a 2009 case (non-binding determination letter, June 6, 2025) https://illinoisfoia.org/opinions/letter-84373/
- Denial based on impoundment order
  Rule: A public body must prove a court order prohibits disclosure; an impoundment order on court copies does not bar releasing the agency's own copies.
  Decision: Communications with a judge about a wrongful death lawsuit (non-binding determination letter, December 20, 2023) https://illinoisfoia.org/opinions/letter-77825/
- Denial of entire email under CRTA confidentiality
  Rule: A public body must redact exempt information and disclose the rest; it cannot withhold an entire record unless every part is exempt.
  Decision: An email about cannabis licensing between a department's deputy director and two others (non-binding determination letter, July 19, 2023) https://illinoisfoia.org/opinions/letter-76546/
- Section 7(1)(a) LEADS data exemption
  Rule: The public body failed to prove the withheld record contained LEADS data or that any specific information derived from LEADS.
  Decision: An email about an incident log (non-binding determination letter, September 28, 2023) https://illinoisfoia.org/opinions/letter-70185/
- Section 7(1)(a) withholding of non-LEADS information
  Rule: General information obtained from LEADS and incorporated into an investigative report is not exempt under section 7(1)(a).
  Decision: An applicant's background check and polygraph records (non-binding determination letter, May 15, 2024) https://illinoisfoia.org/opinions/letter-69962/
- Withholding photo array and lineup report under section 7(1)(a)
  Rule: Section 107A-2(k) only prohibits disclosure of electronic recordings, not photo arrays or lineup reports, so the Police Department failed to meet its burden.
  Decision: Audio and video recordings of a police photo array (non-binding determination letter, December 2, 2025) https://illinoisfoia.org/opinions/letter-64491/
- Redactions under FERPA and ISSRA exemptions
  Rule: The District failed to prove that all redacted information was exempt under FERPA or ISSRA because some redacted portions could not be linked to a student's identity.
  Decision: A school district's settlement agreement with a student's family (non-binding determination letter, December 15, 2023) https://illinoisfoia.org/opinions/letter-58473/
- Section 7(1)(a) exemption based on Federal FOIA
  Rule: Federal FOIA does not apply to a state public body, so citing federal exemptions cannot justify withholding under section 7(1)(a).
  Decision: Death investigation records and police-federal communications (non-binding determination letter, June 5, 2023) https://illinoisfoia.org/opinions/letter-57377/
- Withholding IRB letters under Medical Studies Act
  Rule: The Medical Studies Act protects deliberative peer review materials but not the IRB's findings and corrective actions, which must be disclosed.
  Decision: An internal investigation into a professor's research and IRB process (non-binding determination letter, February 1, 2019) https://illinoisfoia.org/opinions/letter-53007/
- Notice to remedy not a performance evaluation under FOIA 7(1)(a) and 7.5(q)
  Rule: A notice to remedy addresses specific misconduct, not a periodic comprehensive performance evaluation, so it is not exempt under PRRA or School Code.
  Decision: An exhibit to a teacher's notice to remedy resolution (non-binding determination letter, September 13, 2017) https://illinoisfoia.org/opinions/letter-47540/
- Improper denial under section 7(1)(a) and UCC 3-2-5(c)
  Rule: To withhold under 7(1)(a), the public body must show the records are specifically prohibited by law; IDOC failed to prove the records were both collected and maintained by the gang intelligence unit.
  Decision: A corrections department's gang renunciation program records (non-binding determination letter, March 7, 2017) https://illinoisfoia.org/opinions/letter-45170/

NO VIOLATION (19):
- Denial of FOIA request for genetic phenotype report
  Rule: FOIA exempts information specifically prohibited from disclosure by state law, and GIPA prohibits disclosure of genetic testing information except to authorized persons or for criminal investigation.
  Decision: DNA phenotype reports for an unsolved murder case (non-binding determination letter, June 11, 2026) https://illinoisfoia.org/opinions/letter-94362/
- Denial of minor's law enforcement records under FOIA
  Rule: FOIA exempts information prohibited from disclosure by state law, and the Juvenile Court Act prohibits disclosure of law enforcement records of a minor to unauthorized persons.
  Decision: Law enforcement records of a minor's arrest (non-binding determination letter, March 30, 2018) https://illinoisfoia.org/opinions/letter-52318/
- Withholding of complaints, investigative records, and internal correspondence
  Rule: Records related to the Department's examination or investigation of a mortgage company are exempt as confidential supervisory information under Department rules implementing the Residential Mortgage License Act.
  Decision: Investigative materials and hearing transcripts from a 2013 disciplinary order (non-binding determination letter, September 25, 2025) https://illinoisfoia.org/opinions/letter-89273/
- IDOC denial of master record file request under FOIA exemption
  Rule: IDOC properly denied a request for master record files because the Unified Code of Corrections limits access to authorized personnel, court order, or subpoena, and does not allow access by an investigator or attorney even with a client release.
  Decision: An inmate's discharge date from a corrections sentence (non-binding determination letter, March 17, 2025) https://illinoisfoia.org/opinions/letter-85755/
- Hot List or Hot Plates reports exempt
  Rule: LEADS data is exempt from disclosure under FOIA section 7(1)(a) because administrative rules prohibit dissemination to unauthorized individuals, and the public is not authorized.
  Decision: Police records on Automated License Plate Reader data and investigations (non-binding determination letter, January 27, 2025) https://illinoisfoia.org/opinions/letter-84561/
- Withholding records sealed by court order
  Rule: A public body does not violate FOIA when it withholds records that are prohibited from disclosure by a court order, such as a sealing order.
  Decision: Police reports from a 2009 case (non-binding determination letter, June 6, 2025) https://illinoisfoia.org/opinions/letter-84373/
- Copyright law prohibits disclosure of embedded software information
  Rule: FOIA exempts information specifically prohibited from disclosure by federal law, and copyright law prohibits reproducing copyrighted software including embedded information.
  Decision: A proprietary cost table in assessment software (non-binding determination letter, March 3, 2025) https://illinoisfoia.org/opinions/letter-84329/
- Withholding REACH test results as teacher performance evaluations
  Rule: Records that are teacher performance evaluations are exempt from FOIA disclosure under the School Code and Personnel Record Review Act, and must be withheld in full without redaction.
  Decision: Teacher evaluation performance task results (non-binding determination letter, July 9, 2024) https://illinoisfoia.org/opinions/letter-81858/
- Closed session verbatim recording exempt under FOIA
  Rule: OMA section 2.06(e) prohibits disclosure of closed session verbatim recordings unless the public body determines they no longer require confidential treatment.
  Decision: Closed-session minutes and recordings of an investigation (non-binding determination letter, May 20, 2024) https://illinoisfoia.org/opinions/letter-81399/
- Denial of library cardholder names under FOIA exemption
  Rule: Library registration records are confidential under the Library Records Confidentiality Act and exempt from FOIA disclosure under section 7(1)(a).
  Decision: List of adult library cardholders (non-binding determination letter, April 25, 2024) https://illinoisfoia.org/opinions/letter-81001/
- Withholding case records under FOIA section 7(1)(a)
  Rule: The Public Aid Code prohibits disclosure of public aid records except for purposes directly connected with administering public aid, so the exemption applies.
  Decision: Personal case file records of a state human services agency (non-binding determination letter, October 17, 2023) https://illinoisfoia.org/opinions/letter-78380/
- Withholding investigative records under section 7(1)(a)
  Rule: The Department properly withheld investigative case file materials because no formal complaint or disciplinary order was issued, making the confidentiality provisions applicable.
  Decision: Disciplinary case files of a state regulatory agency (non-binding determination letter, July 12, 2023) https://illinoisfoia.org/opinions/letter-76415/
- Denial of FOIA request for firearms restraining order data
  Rule: ISP properly denied the request because the responsive data is maintained in LEADS, and state law and administrative rules prohibit disclosure of LEADS data to unauthorized parties.
  Decision: Spreadsheet of firearms restraining order data (non-binding determination letter, April 20, 2023) https://illinoisfoia.org/opinions/letter-73240/
- Section 7(1)(a) withholding of LEADS data
  Rule: LEADS data is specifically prohibited from disclosure to unauthorized individuals, including the requester.
  Decision: An applicant's background check and polygraph records (non-binding determination letter, May 15, 2024) https://illinoisfoia.org/opinions/letter-69962/
- Permissible redactions under 7(1)(a), 7(1)(c), 7(1)(d)(iv)
  Rule: The public body may redact mental health records, personal information of crime victims, and identities of confidential sources or complainants.
  Decision: Emails between four individuals over three months (non-binding determination letter, July 18, 2023) https://illinoisfoia.org/opinions/letter-69899/
- Withholding ARDC investigation records under Rule 766
  Rule: Records relating to ARDC investigations are private and confidential under Rule 766 and thus exempt from disclosure under section 7(1)(a) of FOIA.
  Decision: Complaints and investigative files about a school district's general counsel (non-binding determination letter, January 13, 2023) https://illinoisfoia.org/opinions/letter-64820/
- Withholding lineup recordings under section 7(1)(a)
  Rule: Section 107A-2(k) of the Criminal Code prohibits disclosure of electronic recordings made during a lineup, regardless of whether an independent administrator oversaw the lineup.
  Decision: Audio and video recordings of a police photo array (non-binding determination letter, December 2, 2025) https://illinoisfoia.org/opinions/letter-64491/
- Body camera footage withheld under section 7(1)(a)
  Rule: Supreme Court Rule 63 designates recordings from security cameras monitoring court facilities as circuit court property, so the footage is not subject to FOIA and the Sheriff's Office did not violate FOIA by withholding it.
  Decision: Police body-camera footage of a courthouse incident (non-binding determination letter, June 21, 2018) https://illinoisfoia.org/opinions/letter-52871/
- Section 7(1)(a) exemption for Medicaid Act confidentiality
  Rule: Records concerning public aid applicants and recipients are exempt from disclosure when federal law prohibits disclosure except for purposes directly connected with administering the plan.
  Decision: Public aid assistance records (non-binding determination letter, February 25, 2016) https://illinoisfoia.org/opinions/letter-38676/

MOST-CITED AUTHORITIES: Better Gov't Ass'n v. Zaruba, 2014 IL App (2d) 140071, ¶ 27; Better Gov't Ass'n v. Blagojevich, 386 Ill. App. 3d 808, 816 (4th Dist. 2008); Wisnasky-Bettorf v. Pierce, 2012 IL 111253; Southern Illinoisan v. Illinois Department of Public Health, 218 Ill. 2d 390, 844 N.E.2d 1 (2006); Lieber v. Board of Trustees of Southern Illinois University, 176 Ill. 2d 401, 407 (1997); Bright v. Dicke, 166 Ill. 2d 204, 210 (1995)

TASK FOR THE ASSISTANT: Using only the decisions above, help draft a letter. Argue from the rule and cite the decision by name and date. Do not invent decisions.

Violation found (13)

Redaction under section 7(1)(a) and JCA
Rule: The JCA restricts juvenile law enforcement records, but the report did not concern a minor's investigation, arrest, or custodial detention, so the exemption did not apply.
Violation found A police report of a DUI arrest and vehicle impoundment · August 21, 2024
ISP improperly withheld documents under MHDDCA confidentiality
Rule: MHDDCA confidentiality applies only to records and communications made in the course of providing mental health services, not to law enforcement investigatory records merely because they pertain to a named resident.
Violation found Police reports of a 1969 death at a state hospital · September 8, 2025
Withholding records not covered by sealing order
Rule: A public body must demonstrate by clear and convincing evidence that withheld records are covered by a court order sealing them; otherwise, the denial is improper.
Violation found Police reports from a 2009 case · June 6, 2025
Denial based on impoundment order
Rule: A public body must prove a court order prohibits disclosure; an impoundment order on court copies does not bar releasing the agency's own copies.
Violation found Communications with a judge about a wrongful death lawsuit · December 20, 2023
Denial of entire email under CRTA confidentiality
Rule: A public body must redact exempt information and disclose the rest; it cannot withhold an entire record unless every part is exempt.
Violation found An email about cannabis licensing between a department's deputy director and two others · July 19, 2023
Section 7(1)(a) LEADS data exemption
Rule: The public body failed to prove the withheld record contained LEADS data or that any specific information derived from LEADS.
Violation found An email about an incident log · September 28, 2023
Section 7(1)(a) withholding of non-LEADS information
Rule: General information obtained from LEADS and incorporated into an investigative report is not exempt under section 7(1)(a).
Violation found An applicant's background check and polygraph records · May 15, 2024
Withholding photo array and lineup report under section 7(1)(a)
Rule: Section 107A-2(k) only prohibits disclosure of electronic recordings, not photo arrays or lineup reports, so the Police Department failed to meet its burden.
Violation found Audio and video recordings of a police photo array · December 2, 2025
Redactions under FERPA and ISSRA exemptions
Rule: The District failed to prove that all redacted information was exempt under FERPA or ISSRA because some redacted portions could not be linked to a student's identity.
Violation found A school district's settlement agreement with a student's family · December 15, 2023
Section 7(1)(a) exemption based on Federal FOIA
Rule: Federal FOIA does not apply to a state public body, so citing federal exemptions cannot justify withholding under section 7(1)(a).
Violation found Death investigation records and police-federal communications · June 5, 2023
Withholding IRB letters under Medical Studies Act
Rule: The Medical Studies Act protects deliberative peer review materials but not the IRB's findings and corrective actions, which must be disclosed.
Violation found An internal investigation into a professor's research and IRB process · February 1, 2019
Notice to remedy not a performance evaluation under FOIA 7(1)(a) and 7.5(q)
Rule: A notice to remedy addresses specific misconduct, not a periodic comprehensive performance evaluation, so it is not exempt under PRRA or School Code.
Violation found An exhibit to a teacher's notice to remedy resolution · September 13, 2017
Improper denial under section 7(1)(a) and UCC 3-2-5(c)
Rule: To withhold under 7(1)(a), the public body must show the records are specifically prohibited by law; IDOC failed to prove the records were both collected and maintained by the gang intelligence unit.
Violation found A corrections department's gang renunciation program records · March 7, 2017

No violation (19)

Denial of FOIA request for genetic phenotype report
Rule: FOIA exempts information specifically prohibited from disclosure by state law, and GIPA prohibits disclosure of genetic testing information except to authorized persons or for criminal investigation.
No violation DNA phenotype reports for an unsolved murder case · June 11, 2026
Denial of minor's law enforcement records under FOIA
Rule: FOIA exempts information prohibited from disclosure by state law, and the Juvenile Court Act prohibits disclosure of law enforcement records of a minor to unauthorized persons.
No violation Law enforcement records of a minor's arrest · March 30, 2018
Withholding of complaints, investigative records, and internal correspondence
Rule: Records related to the Department's examination or investigation of a mortgage company are exempt as confidential supervisory information under Department rules implementing the Residential Mortgage License Act.
No violation Investigative materials and hearing transcripts from a 2013 disciplinary order · September 25, 2025
IDOC denial of master record file request under FOIA exemption
Rule: IDOC properly denied a request for master record files because the Unified Code of Corrections limits access to authorized personnel, court order, or subpoena, and does not allow access by an investigator or attorney even with a client release.
No violation An inmate's discharge date from a corrections sentence · March 17, 2025
Hot List or Hot Plates reports exempt
Rule: LEADS data is exempt from disclosure under FOIA section 7(1)(a) because administrative rules prohibit dissemination to unauthorized individuals, and the public is not authorized.
No violation Police records on Automated License Plate Reader data and investigations · January 27, 2025
Withholding records sealed by court order
Rule: A public body does not violate FOIA when it withholds records that are prohibited from disclosure by a court order, such as a sealing order.
No violation Police reports from a 2009 case · June 6, 2025
Copyright law prohibits disclosure of embedded software information
Rule: FOIA exempts information specifically prohibited from disclosure by federal law, and copyright law prohibits reproducing copyrighted software including embedded information.
No violation A proprietary cost table in assessment software · March 3, 2025
Withholding REACH test results as teacher performance evaluations
Rule: Records that are teacher performance evaluations are exempt from FOIA disclosure under the School Code and Personnel Record Review Act, and must be withheld in full without redaction.
No violation Teacher evaluation performance task results · July 9, 2024
Closed session verbatim recording exempt under FOIA
Rule: OMA section 2.06(e) prohibits disclosure of closed session verbatim recordings unless the public body determines they no longer require confidential treatment.
No violation Closed-session minutes and recordings of an investigation · May 20, 2024
Denial of library cardholder names under FOIA exemption
Rule: Library registration records are confidential under the Library Records Confidentiality Act and exempt from FOIA disclosure under section 7(1)(a).
No violation List of adult library cardholders · April 25, 2024
Withholding case records under FOIA section 7(1)(a)
Rule: The Public Aid Code prohibits disclosure of public aid records except for purposes directly connected with administering public aid, so the exemption applies.
No violation Personal case file records of a state human services agency · October 17, 2023
Withholding investigative records under section 7(1)(a)
Rule: The Department properly withheld investigative case file materials because no formal complaint or disciplinary order was issued, making the confidentiality provisions applicable.
No violation Disciplinary case files of a state regulatory agency · July 12, 2023
Denial of FOIA request for firearms restraining order data
Rule: ISP properly denied the request because the responsive data is maintained in LEADS, and state law and administrative rules prohibit disclosure of LEADS data to unauthorized parties.
No violation Spreadsheet of firearms restraining order data · April 20, 2023
Section 7(1)(a) withholding of LEADS data
Rule: LEADS data is specifically prohibited from disclosure to unauthorized individuals, including the requester.
No violation An applicant's background check and polygraph records · May 15, 2024
Permissible redactions under 7(1)(a), 7(1)(c), 7(1)(d)(iv)
Rule: The public body may redact mental health records, personal information of crime victims, and identities of confidential sources or complainants.
No violation Emails between four individuals over three months · July 18, 2023
Withholding ARDC investigation records under Rule 766
Rule: Records relating to ARDC investigations are private and confidential under Rule 766 and thus exempt from disclosure under section 7(1)(a) of FOIA.
No violation Complaints and investigative files about a school district's general counsel · January 13, 2023
Withholding lineup recordings under section 7(1)(a)
Rule: Section 107A-2(k) of the Criminal Code prohibits disclosure of electronic recordings made during a lineup, regardless of whether an independent administrator oversaw the lineup.
No violation Audio and video recordings of a police photo array · December 2, 2025
Body camera footage withheld under section 7(1)(a)
Rule: Supreme Court Rule 63 designates recordings from security cameras monitoring court facilities as circuit court property, so the footage is not subject to FOIA and the Sheriff's Office did not violate FOIA by withholding it.
No violation Police body-camera footage of a courthouse incident · June 21, 2018
Section 7(1)(a) exemption for Medicaid Act confidentiality
Rule: Records concerning public aid applicants and recipients are exempt from disclosure when federal law prohibits disclosure except for purposes directly connected with administering the plan.
No violation Public aid assistance records · February 25, 2016