https://illinoisfoia.org/exemptions/7-1-a/ 2026-06-11T00:00:00Z https://illinoisfoia.org/opinions/letter-94362/ 2026-06-11T00:00:00Z

Under FOIA, a public body may withhold records if another statute specifically prohibits disclosure. Here, the Genetic Information Privacy Act (GIPA) sections 15(a) and 15(b) bar the Sheriff's Office from disclosing genetic testing reports derived from a biological sample. Because the requested Parabon Nanolabs phenotype report is exactly that type of record, the denial was proper and no further action was warranted.

https://illinoisfoia.org/opinions/10-001-2/ 2026-06-09T00:00:00Z

This document is not a legal decision, but rather a master list or index of all binding opinions issued by the Illinois Attorney General's Public Access Counselor since 2010. It is intended to help the public and legal professionals find specific past rulings on Freedom of Information Act (FOIA) issues.

https://illinoisfoia.org/opinions/2025-pac-89395/ 2025-12-31T00:00:00Z

The requester sought an unredacted copy of a village clerk's termination letter, which the village withheld citing personnel-record and workplace-privacy statutes and FOIA's personal-privacy and disciplinary-adjudication exemptions. The Public Access Counselor held that no cited statute prohibited disclosure of the letter, that it concerned the performance of public duties rather than private affairs, and that the village had not shown any formal adjudication occurred. The village was directed t

https://illinoisfoia.org/opinions/letter-89273/ 2025-09-25T00:00:00Z

A requester asked for records related to a 2013 disciplinary case, but the Department only provided a single order. The requester complained to the Attorney General's office, believing more records should exist. The PAC found that the Department does not actually have the additional records requested and that other parts of the file are legally protected from release.

https://illinoisfoia.org/opinions/2025-pac-86098/ 2025-07-15T00:00:00Z

The requester, a reporter, sought an attachment to a school board president's email forwarding a former law firm's correspondence to board members, which a school district withheld citing attorney-client, deliberative-process, and other exemptions. The Public Access Counselor held that the record did not reflect legal advice sought from or given by the district's former attorney, did not represent the district's own predecisional deliberations, and was not otherwise shown to be legally confident

https://illinoisfoia.org/opinions/letter-85453/ 2025-06-13T00:00:00Z

A researcher requested applications for a state tax incentive program, but the DCEO refused to release them, claiming they were still under review and part of a deliberative process. The Attorney General's office disagreed, ruling that the records are public and must be released. The agency is allowed to redact specific private financial or commercial data before providing the documents.

https://illinoisfoia.org/opinions/letter-84373/ 2025-06-06T00:00:00Z

A citizen requested police records, but the Wheaton Police Department denied the request, claiming the records were sealed by a court order. The Attorney General's office reviewed the documents and found that while most of the records were correctly withheld, some pages did not relate to the sealed case. The PAC concluded the Department must release those specific pages.

https://illinoisfoia.org/opinions/letter-85755/ 2025-03-17T00:00:00Z

A federal investigator asked the Illinois Department of Corrections for an inmate's release date, but the department refused to provide it. The Attorney General's office reviewed the case and agreed with the department, explaining that state law strictly limits who can access these specific records and a signed release from the inmate does not override those legal restrictions. Consequently, the case is closed with no further action required.

https://illinoisfoia.org/opinions/letter-84329/ 2025-03-03T00:00:00Z

A citizen asked the Marion County Assessor's Office for a copy of a Marshall & Swift cost table embedded in the DEVNET software used to calculate property assessments. The Illinois Attorney General's Public Access Bureau determined the request was unfounded because the embedded table is exempt from disclosure under FOIA section 7(1)(o) as administrative or technical information associated with automated data processing, and also exempt under section 7(1)(a) because the software is protected by f

https://illinoisfoia.org/opinions/letter-84605/ 2025-01-08T00:00:00Z

A requester asked the Chicago Police Department for juvenile criminal records of a deceased person. The police denied the request, stating that juvenile records are confidential by law. The Attorney General's office agreed, confirming that the law protecting juvenile records remains in effect even after the minor is deceased.

https://illinoisfoia.org/opinions/letter-84370/ 2024-12-20T00:00:00Z

A requester asked the Chicago Office of Emergency Management and Communications (OEMC) for video footage of a shooting, but OEMC denied the request, citing that releasing the video could interfere with an active police investigation. The Illinois Attorney General's Public Access Bureau reviewed the case and determined that no further action was warranted because the footage was exempt from disclosure under FOIA's law enforcement proceedings exemption. This means the request was denied for now, b

https://illinoisfoia.org/opinions/letter-83212/ 2024-10-02T00:00:00Z

This determination addressed whether the Village of Libertyville properly withheld police reports under section 7(1)(c) of FOIA's personal privacy exemption. The Public Access Bureau held that the Village did not improperly withhold the reports, finding the request unfounded. The reports concerned a private incident at a private residence involving named individuals, no arrests or charges resulted, and because the request itself identified the subjects by name and address, redaction would not ha

https://illinoisfoia.org/opinions/letter-83088/ 2024-10-01T00:00:00Z

A citizen asked a school district for reports on student fights and disciplinary actions. The school district refused to provide them, arguing that even if names were removed, the details would still allow people to identify the students involved. The Attorney General's office agreed that the records are protected by privacy laws and closed the case.

https://illinoisfoia.org/opinions/letter-82136/ 2024-08-21T00:00:00Z

A public body must prove by clear and convincing evidence that an exemption applies. The police department redacted a DUI arrest report under 7(1)(a) (information prohibited from disclosure by other law, here the Juvenile Court Act), 7(1)(b) (private information), 7(1)(c) (personal privacy) and 7(1)(d)(iv) (identity of persons who provide information to law enforcement). The PAC accepted redactions of items expressly defined as private information, such as unique identifiers, and of the minor's

https://illinoisfoia.org/opinions/letter-82350/ 2024-08-12T00:00:00Z

A citizen requested records from the Illinois Department on Aging concerning allegations of elder abuse or isolation. The Department refused to release the documents, stating they are confidential by law. The Attorney General's office agreed with the Department, concluding that the records are legally protected and cannot be released without specific authorization.

https://illinoisfoia.org/opinions/letter-81858/ 2024-07-09T00:00:00Z

A requester asked Chicago Public Schools for teacher evaluation data, hoping that removing personal names would make the records public. The Attorney General's office agreed with the school district that these specific evaluation records are protected by law and cannot be released, even if names are removed. Consequently, the PAC closed the case without requiring the district to provide the documents.

https://illinoisfoia.org/opinions/letter-80023/ 2024-06-06T00:00:00Z

A citizen requested emails from a Village, but the Village withheld some of them, claiming they were protected by legal and insurance-related exemptions. The Attorney General's office reviewed the records and agreed that the Village was legally allowed to keep those specific emails private. As a result, the case is closed with no further action required.

https://illinoisfoia.org/opinions/letter-81399/ 2024-05-20T00:00:00Z

A library patron requested records from a closed-door meeting regarding an investigation into their own conduct. The library refused to release the meeting minutes and audio recording, citing laws that keep such records confidential. The Attorney General's office agreed with the library, noting that these records are protected and no further action will be taken.

https://illinoisfoia.org/opinions/letter-69962/ 2024-05-15T00:00:00Z

A job applicant requested her own background check and polygraph results from the Romeoville Police Department, but the department refused to release them. The Attorney General's office reviewed the records and found that the police department failed to prove that all the withheld information was legally exempt. The department was asked to release the non-exempt portions of the records.

https://illinoisfoia.org/opinions/letter-78934/ 2024-05-07T00:00:00Z

A requester asked the University of Illinois for specific statistical summaries of student survey results. The University denied parts of the request, and the PAC found that since the University did not already have the data in the requested format, they were not legally required to create it. The case was closed without a formal violation finding.

https://illinoisfoia.org/opinions/letter-76612/ 2024-05-06T00:00:00Z

A citizen requested squad camera and body worn camera footage of a traffic stop from the Illinois State Police. The police placed the request on a waitlist, required the requester to fill out a form, and assessed fees to provide the footage. The Public Access Bureau of the Illinois Attorney General's office concluded that the police improperly required the form and fees, and that FOIA does not permit charging fees for the video recordings.

https://illinoisfoia.org/opinions/letter-81001/ 2024-04-25T00:00:00Z

A requester asked for a list of all adult library cardholders at the Hinsdale Public Library. The Library refused to provide the list, citing a state law that keeps library registration records private. The Attorney General's office agreed with the Library, confirming that these records are legally protected and do not have to be released.

https://illinoisfoia.org/opinions/letter-58473/ 2023-12-15T00:00:00Z

A reporter asked a school district for a copy of a legal settlement agreement involving a student. The school district blacked out large portions, claiming they were protected student records under state and federal law. The Illinois Attorney General's office reviewed the document and found that the district did not prove by clear and convincing evidence that all of the redacted information was exempt from disclosure, noting that some limited information did not appear to be individually attribu

https://illinoisfoia.org/opinions/letter-78380/ 2023-10-17T00:00:00Z

A citizen requested their own case file and related communications from the Illinois Department of Human Services. The Department denied the request, citing state laws that protect public assistance records from disclosure. The Attorney General's office agreed with the Department, noting that these records are legally confidential and that the requester should follow the Department's suggested process for accessing their own file outside of FOIA.

https://illinoisfoia.org/opinions/letter-70185/ 2023-09-28T00:00:00Z

A journalist requested an email from the Cook County Sheriff's Office, which the office refused to release by claiming it was exempt from disclosure. The Attorney General's Public Access Counselor reviewed the email and found that the Sheriff's Office did not provide enough evidence to justify keeping it secret. Consequently, the PAC asked the Sheriff's Office to release the email to the requester.

https://illinoisfoia.org/opinions/2023-pac-76670/ 2023-07-12T00:00:00Z

The requester, a newspaper reporter, sought police reports about an altercation at a high school in which both an adult and a minor were arrested, and a village disclosed only the adult's basic arrest information under FOIA's police-blotter provision while withholding the police reports themselves. The Public Access Counselor held that because the reports also concerned the investigation and arrest of a minor, the Juvenile Court Act barred their disclosure in their entirety, even as to the porti

https://illinoisfoia.org/opinions/letter-76415/ 2023-07-12T00:00:00Z

A requester asked the Illinois Department of Financial and Professional Regulation (IDFPR) for records regarding two specific disciplinary cases. The IDFPR refused to provide the records, arguing that state law requires them to keep those specific investigation files confidential. The Attorney General's office agreed with the agency, finding that the records were legally exempt from disclosure.

https://illinoisfoia.org/opinions/letter-71823/ 2023-06-23T00:00:00Z

A requester asked the DeKalb County Housing Authority for personnel files of three employees, and later submitted requests for the same records for six other employees. The Housing Authority released some records but redacted many categories, including footnotes, employment applications, retirement investment elections, social security cards, driver's licenses, and middle initials. The Illinois Attorney General's Public Access Bureau reviewed the redactions and determined that the footnotes were

https://illinoisfoia.org/opinions/letter-57377/ 2023-06-05T00:00:00Z

A reporter requested police records about a death investigation from the Park Ridge Police Department, which refused to provide them, citing federal FOIA exemptions. The Illinois Attorney General's Public Access Bureau reviewed the case and determined that the department's response violated the Illinois Freedom of Information Act because the department, as a state public body, could not rely on federal FOIA exemptions. The determination does not specify any remedy or order to release the records

https://illinoisfoia.org/opinions/letter-73240/ 2023-04-20T00:00:00Z

A reporter asked the Illinois State Police for specific details about firearms restraining orders. The police denied the request, explaining that this information is stored in a restricted law enforcement database that they are legally prohibited from sharing with the public. The Attorney General's office agreed with the police, finding that the law does not allow the release of this specific data.

https://illinoisfoia.org/opinions/letter-64820/ 2023-01-13T00:00:00Z

A requester asked Chicago Public Schools for legal records and complaints involving their General Counsel. The school district refused to release the documents, arguing that a specific Illinois Supreme Court rule requires these types of records to remain confidential. The Attorney General's office agreed with the district, concluding that the records were properly withheld.

https://illinoisfoia.org/opinions/2022-pac-73136/ 2022-11-22T00:00:00Z

The requester, a newspaper reporter, sought a letter a private attorney had sent a city department concerning a legal dispute, which the department withheld as protected by evidentiary and discovery rules governing settlement negotiations and as deliberative material. The Public Access Counselor held that court rules restricting the admissibility of settlement communications in litigation have no bearing on the public's right to records under FOIA, and that the letter, prepared by a third party

https://illinoisfoia.org/opinions/letter-70844/ 2022-07-01T00:00:00Z

The Freedom Foundation asked Cook County School District 130 for a list of employees covered by a collective bargaining agreement with SEIU Local 73, including their names and job details. The school district refused to provide this information, citing privacy and labor laws. The Attorney General's office agreed with the school district, ruling that state law protects this type of union-related employee information from being released through a FOIA request because disclosing which employees are

https://illinoisfoia.org/opinions/2020-pac-65525/ 2021-02-17T00:00:00Z

The requester, a newspaper reporter, sought police records concerning an alleged sexual-offense complaint against a named adult connected to a church, and a police department withheld the records in full, initially citing the Juvenile Court Act. The Public Access Counselor held that the Act did not apply because the accused was an adult, but that a separate personal-privacy exemption did apply because the alleged victim was a minor and the accused was never arrested or charged, so the significan

https://illinoisfoia.org/opinions/2020-pac-65160/ 2021-01-26T00:00:00Z

The requester, a newspaper reporter, sought copies of federal subpoenas and search warrants served on a city police department in a given month, which the department denied as unduly burdensome without ever engaging with the requester's repeated attempts to confer about narrowing the request. The Public Access Counselor held that the department violated FOIA's mandatory duty to offer and follow through on conferring before denying a request as unduly burdensome, and separately failed to prove ei

https://illinoisfoia.org/opinions/2020-pac-64668/ 2020-12-21T00:00:00Z

The requester, an attorney representing the father of a minor sexual-assault victim, sought a police report about the assault, which a sheriff's office withheld in full under the Juvenile Court Act because a minor was named in the report. The Public Access Counselor held that the Act's confidentiality provisions protect records concerning minors suspected of offenses, not minor victims, and that because the alleged suspect was an adult, the Act did not authorize withholding the report. The sheri

https://illinoisfoia.org/opinions/letter-61760/ 2020-08-31T00:00:00Z

A requester asked the City of Peoria for records regarding misconduct complaints against two employees. The City withheld some information, claiming it was private or exempt, but the Attorney General's office found that some of those redactions were improper and requested the City release the specific portions of the documents.

https://illinoisfoia.org/opinions/2020-pac-61510/ 2020-05-08T00:00:00Z

The requester, a newspaper, sought cannabis cultivation license applications from a state agency, which redacted the names and addresses of company principals and board members, citing confidentiality provisions of a separate medical cannabis law and privacy exemptions. The Public Access Counselor held that the medical cannabis confidentiality provisions did not extend to applications submitted under the adult-use cannabis licensing law, which instead makes such applications subject to FOIA and

https://illinoisfoia.org/opinions/letter-61358/ 2020-02-26T00:00:00Z

The question was whether the Town of Cicero improperly withheld police disciplinary-file records under FOIA when a federal court's confidentiality order barred their disclosure. The Public Access Bureau held that the Town did not violate FOIA, because a public body does not violate the Act when it withholds records that a binding court order prohibits it from disclosing. The Town produced the underlying confidentiality order from a related federal lawsuit, and the Bureau confirmed with the Town'

https://illinoisfoia.org/opinions/2019-pac-58547/ 2019-09-24T00:00:00Z

The requester, a newspaper reporter, sought police reports concerning two arrests, and the police department redacted nearly all of the narrative sections citing exemptions for private information, personal privacy, fair-trial interference, and confidential sources. The Public Access Counselor held that most of the redactions were improper because arrests are matters of legitimate public interest and the department did not show a specific fair-trial risk, but agreed that the department could red

https://illinoisfoia.org/opinions/letter-57517/ 2019-08-01T00:00:00Z

An attorney sought body-camera recordings of a traffic accident on behalf of a client, which the police department withheld under the Body Camera Act. The PAC determined the client did not appear on the recordings and was therefore not the "subject of the encounter" entitled to obtain them, and the recordings were not otherwise flagged for release under the Act's disclosure triggers. The department's withholding did not violate FOIA.

https://illinoisfoia.org/opinions/2019-pac-58962/ 2019-07-01T00:00:00Z

The requester, a community advocate, sought dashboard and body camera recordings of an in-custody death, which a city withheld citing multiple law-enforcement exemptions tied to open state police and other investigations into the incident. The Public Access Counselor held that because the recordings were flagged under the Law Enforcement Officer-Worn Body Camera Act as involving death or bodily harm, they were subject to disclosure unless the city proved an exemption applied, and the city's asse

https://illinoisfoia.org/opinions/letter-53007/ 2019-02-01T00:00:00Z

A reporter requested records from the University of Illinois regarding an investigation into a professor's research. The University redacted or withheld portions of the records, citing exemptions under state and federal law. The Illinois Attorney General's Public Access Bureau concluded that the University improperly denied portions of the records responsive to the requests.

https://illinoisfoia.org/opinions/2018-pac-55193/ 2019-01-09T00:00:00Z

The requester, a law firm representing the subject of a police encounter, sought body-worn camera video related to a motor vehicle collision after the police department withheld it on the theory that footage must first be formally "flagged" before it could be disclosed to the subject or the subject's attorney. The Public Access Counselor held that the Law Enforcement Officer-Worn Body Camera Act separately requires disclosure of recordings to the subject of the encounter or the subject's attorne

https://illinoisfoia.org/opinions/letter-52871/ 2018-06-21T00:00:00Z

A requester asked for police body camera footage of an incident at a courthouse. The Sheriff's Office refused to release the video, and the Attorney General's office agreed that the refusal was lawful. This means the public does not have a right to access this specific footage under FOIA.

https://illinoisfoia.org/opinions/letter-52318/ 2018-03-30T00:00:00Z

FOIA exempts records that are specifically prohibited from disclosure by other state or federal laws. Here, the Juvenile Court Act prohibits releasing law enforcement records concerning a minor who has violated a law, defining such a minor as a 'delinquent minor.' Because the arrested individual was under 18, the Sheriff's Office correctly withheld the records under FOIA section 7(1)(a), which incorporates that statutory bar. The PAC therefore found no violation, though it noted the requester co

https://illinoisfoia.org/opinions/2017-pac-49564/ 2017-11-07T00:00:00Z

The requester, a newspaper reporter, sought audio recordings of the housing authority board's open meetings from a given year, and the housing authority withheld them as preliminary, deliberative material. The Public Access Counselor held that a verbatim recording of a meeting that was open to the public is inherently subject to public scrutiny and is not the kind of predecisional record the deliberative-process exemption protects, regardless of the purpose for which the recording was made. The

https://illinoisfoia.org/opinions/letter-47540/ 2017-09-13T00:00:00Z

A newspaper requested a notice to remedy that was attached to a school board resolution, but the district withheld it, claiming it was a confidential performance evaluation. The Illinois Attorney General's Public Access Bureau ruled that the notice to remedy is not a 'performance evaluation' under the School Code or the Personnel Record Review Act because it addresses specific instances of misconduct rather than a comprehensive periodic evaluation. Therefore, the district improperly denied the r

https://illinoisfoia.org/opinions/letter-45170/ 2017-03-07T00:00:00Z

A legal clinic requested general information about the Illinois Department of Corrections' Gang Renunciation program, but the agency denied the request, claiming the information was confidential under state law. The Attorney General's office reviewed the case and found that the IDOC violated FOIA by improperly denying the request. The office also determined that the IDOC failed to provide sufficient evidence to justify the exemption, but the document does not include any order requiring the agen

https://illinoisfoia.org/opinions/letter-37541/ 2016-08-25T00:00:00Z

A reporter requested records regarding a teacher's disciplinary settlement, but the school district blacked out too much information. The Attorney General's office ruled that the district must release the records, only redacting the names of students to protect their privacy. This ensures the public can understand the reasons for the settlement while keeping student identities private.