https://illinoisfoia.org/exemptions/7-1-b/ 2026-09-30T00:00:00Z https://illinoisfoia.org/opinions/2026-pac-95139/ 2026-09-30T00:00:00Z

A public body must prove by clear and convincing evidence that an exemption applies, and exemptions are read narrowly. The sheriff's office denied a request for incident reports about restraint-chair use at the jail in its entirety under the private-information exemption (7(1)(b)) and the personal-privacy exemption (7(1)(c)), then added 7(1)(b-5), which covers law enforcement databases specifically designed to inform officers of a person's physical or mental status. The PAC held that discrete it

https://illinoisfoia.org/opinions/2025-pac-90290/ 2026-02-10T00:00:00Z

The requester, a newspaper reporter, sought communications regarding the employment status of a state's attorney's office employee, and the office withheld her termination letter as interfering with a pending criminal prosecution and jury selection. The Public Access Counselor held that the letter was a personnel record not possessed for a law enforcement purpose and that the office's generalized assertions did not show disclosure would interfere with any proceeding or deprive anyone of a fair t

https://illinoisfoia.org/opinions/letter-64491/ 2025-12-02T00:00:00Z

A citizen requested audio and video recordings of a police photo lineup, as well as the photo array and lineup report, from the Homewood Police Department. The department denied the audio and video recordings under a state law that keeps lineup recordings confidential, and denied the photo array and report under a FOIA exemption for investigative techniques. The Illinois Attorney General's office reviewed the request and found that the audio and video recordings were properly withheld, but the p

https://illinoisfoia.org/opinions/letter-88977/ 2025-09-30T00:00:00Z

A requester asked for specific digital files from the City and the State's Attorney's Office. The PAC found that the government agencies either did not have the records or were not legally required to create new files or answer the requester's specific questions. Consequently, the PAC closed the case without finding any violations.

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-86670/ 2025-08-11T00:00:00Z

The requester, a journalism student working with a nonprofit newsroom, sought records concerning a police officer's separation from the department, which a city public safety office withheld in full as private information and an invasion of personal privacy. The Public Access Counselor held that a public employee's separation records are not "private information" in their entirety and that disclosure of records bearing on a public employee's duties does not constitute an unwarranted invasion of

https://illinoisfoia.org/opinions/letter-85480/ 2025-07-29T00:00:00Z

A mother requested police reports and body camera footage related to an incident involving her son. The Sheriff's Office provided redacted reports and withheld the video, citing privacy concerns. The Attorney General's office reviewed the materials and agreed that the Sheriff's Office acted within the law to protect the privacy of the individuals involved.

https://illinoisfoia.org/opinions/letter-86577/ 2025-05-27T00:00:00Z

FOIA's private-information exemption (7(1)(b)) protects a person's home address and its component parts unless another law requires disclosure or the data cannot be attributed to any person. The requester asked a city for each employee's home zip code alongside names and compensation. The PAC concluded that a zip code paired with an employee's name could lead to the employee's home address through commonly available sources, so the city properly withheld it, and it distinguished an appellate dec

https://illinoisfoia.org/opinions/letter-86210/ 2025-05-13T00:00:00Z

A citizen requested a police report regarding a medical incident involving their mother-in-law, but the police department redacted personal information. The PAC ruled that the department acted correctly because the requester did not provide written consent or legal authorization from the individual named in the report. The requester may submit a new request if they obtain the necessary written consent from the subject.

https://illinoisfoia.org/opinions/letter-86063/ 2025-04-22T00:00:00Z

A citizen requested business licensing and enforcement records from the City of Centralia, but the City partially denied the request, citing exemptions for private information, attorney-client communications, and examination data. The citizen challenged the partial denial, arguing the search was insufficient and the exemptions were misapplied. The Public Access Bureau of the Illinois Attorney General reviewed the records and concluded that the City conducted a reasonable search and properly appl

https://illinoisfoia.org/opinions/letter-85584/ 2025-03-27T00:00:00Z

A law firm requested an unredacted police crash report to help them serve legal papers to a driver involved in an accident. The Illinois State Police provided the report but redacted private details like the driver's home address and license number. The Attorney General's office agreed with the police, stating these redactions are allowed by law, and suggested the firm use a subpoena to obtain the full information.

https://illinoisfoia.org/opinions/letter-85555/ 2025-03-17T00:00:00Z

This determination letter addresses whether the City of Evanston properly redacted portions of police reports under FOIA sections 7(1)(b) and 7(1)(c). The Public Access Bureau held that the City did not improperly redact the reports, finding that the redacted material constituted private information (home addresses, personal telephone numbers) and information whose disclosure would be an unwarranted invasion of personal privacy, including a caller's statements to police in a domestic incident. T

https://illinoisfoia.org/opinions/letter-85113/ 2025-02-14T00:00:00Z

This determination letter addresses whether the Northfield Police Department properly withheld a complainant's statement to police under FOIA exemptions 7(1)(c) and 7(1)(d)(iv). The Public Access Bureau held that the Department properly withheld the requested information because disclosure would identify a complainant to law enforcement, constituting an unwarranted invasion of personal privacy and unavoidably revealing the identity of a person who provided information to police, even though the

https://illinoisfoia.org/opinions/letter-77465/ 2024-12-30T00:00:00Z

A reporter requested a police report from the Village of Glenview, but the Village denied the request in its entirety, citing exemptions for personal privacy and confidential information. The Attorney General's office reviewed the records and concluded the Village improperly withheld the entire document. The Village must now disclose a version of the report that reveals the officers' activities, but may redact information identifying the complainant, suspect, witnesses, and third parties, as wel

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-80318/ 2024-11-22T00:00:00Z

A reporter requested emails between the University of Illinois athletic department and the Illini Guardians NIL group from January to August 2023. The University redacted some information, citing exemptions for private information, personal privacy, and preliminary drafts. The Illinois Attorney General's office reviewed the redactions and determined that the University properly redacted personal email addresses, phone numbers, passcodes, and one highly personal line under the cited exemptions. T

https://illinoisfoia.org/opinions/letter-80603/ 2024-11-22T00:00:00Z

A requester asked for application scores and evaluation notes from the Illinois Department of Commerce & Economic Opportunity’s state cultural district program. The agency released some records but withheld scoring materials as internal, predecisional deliberative documents. The Public Access Bureau (Attorney General’s office) concluded that the agency did not improperly withhold those records, because the score sheets and notes are exempt from disclosure under section 7(1)(f) of FOIA as prelimi

https://illinoisfoia.org/opinions/letter-62344/ 2024-11-21T00:00:00Z

A requester asked for police records from a 1992 murder case, but the police department blacked out several names. The Attorney General's office reviewed the records and decided that while the police were allowed to hide the names of witnesses and third parties, they were not allowed to hide the names of the people who were arrested. The police have been asked to provide a new copy of the records with the arrestees' names visible.

https://illinoisfoia.org/opinions/2024-pac-81978/ 2024-10-02T00:00:00Z

The requester, a law firm legal assistant, sought 911 call recordings related to a traffic crash and disputed a dispatch center's redaction of the callers' home or personal telephone numbers after it had already disclosed their names. The Public Access Counselor held that home and personal telephone numbers are private information exempt from disclosure without exception, and that the FOIA provision requiring disclosure of traffic-crash witnesses' identities does not extend to their phone number

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-82990/ 2024-09-25T00:00:00Z

A resident requested an unredacted police incident report to get the contact information of another dog owner involved in an incident. The Village redacted the owner's home address and phone number, and the PAC agreed that this information is legally protected as 'private information.' Because the law exempts this data from disclosure, the PAC closed the case without requiring the Village to release it.

https://illinoisfoia.org/opinions/letter-82465/ 2024-09-24T00:00:00Z

This determination addresses whether the Chicago Park District properly withheld portions of a daily police log under FOIA exemption 5 ILCS 140/7(1)(v), which protects vulnerability assessments and security measures from disclosure. The Public Access Bureau held that the Park District failed to meet its burden of proving by clear and convincing evidence that the redacted 'Exterior Premise Check' and 'Interior Premise Check' entries qualified for the exemption, because the log reflected only rout

https://illinoisfoia.org/opinions/2024-pac-82164/ 2024-09-20T00:00:00Z

The requester sought the police report and related records from an incident in which he was stopped, searched, and released while photographing nearby police activity, which the police department withheld in full as interfering with a pending law enforcement proceeding. The Public Access Counselor held that the case had been administratively closed and the department's claim of an ongoing multi-agency investigation was unsupported by specific facts, so the department failed to prove the records

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-81969/ 2024-08-02T00:00:00Z

This determination addresses whether the City of the requester Office of the Mayor properly withheld portions of e-mails under section 7(1)(f) of FOIA (5 ILCS 140/7(1)(f)) as predecisional, deliberative material. The Public Access Bureau held that the Mayor's Office did not improperly deny the request, because its confidential review confirmed the withheld draft presentation and meeting notes concerning a redevelopment project were predecisional and deliberative when created. The Bureau explaine

https://illinoisfoia.org/opinions/letter-66688/ 2024-06-18T00:00:00Z

A reporter requested police records, which the City of Joliet provided with redactions, claiming the information was protected by attorney-client privilege. The Attorney General's office reviewed the records and found that the redacted parts were merely factual status updates, not legal advice. Consequently, the City was asked to release the unredacted information to the reporter.

https://illinoisfoia.org/opinions/letter-77078/ 2024-05-23T00:00:00Z

A requester asked the City of Springfield for a large volume of emails over a multi-year period. The City claimed the request was too broad and burdensome to fulfill, and the PAC agreed, finding that the effort required to search for and produce the records was not justified by the public interest.

https://illinoisfoia.org/opinions/letter-81205/ 2024-05-08T00:00:00Z

A former employee asked the Chicago Park District for copies of their past performance evaluations. The PAC explained that while employees have a right to see their own personnel files under a different law, FOIA specifically forbids public bodies from releasing performance evaluations. Because the law prohibits these records from being released through a FOIA request, the PAC closed the case.

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-80926/ 2024-05-01T00:00:00Z

A citizen requested a police report, but the Mokena Police Department redacted certain personal details before releasing it. The citizen complained to the Attorney General's office, which reviewed the redactions. The PAC concluded that the police acted legally because the redacted information, such as home addresses and dates of birth, is protected from public disclosure.

https://illinoisfoia.org/opinions/letter-77566/ 2024-04-10T00:00:00Z

A resident requested copies of business leases submitted to the Village of Hanover Park, but the Village refused to provide them, claiming they were exempt from disclosure. The Attorney General's office reviewed the documents and found that the Village's denial was incorrect. The Village must now release the leases to the requester, though they are allowed to black out personal signatures.

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-76460/ 2023-11-21T00:00:00Z

A requester asked for records related to a police chief candidate, including a letter of interest and resume, but the City of Urbana withheld them citing a privacy exemption. The Attorney General's office reviewed the case and determined that the City did not provide clear and convincing evidence that the privacy rights of the candidate outweighed the public interest in disclosure. The determination concludes that the exemption was not proven, but does not explicitly order the release of the rec

https://illinoisfoia.org/opinions/letter-58605/ 2023-10-02T00:00:00Z

A reporter requested records about a fatal crash from a police department. The PAC found that witness statements and information identifying an unarrested suspect could be withheld under the ongoing-investigation exemption, but the department had not shown that the remaining information was exempt. It was asked to provide redacted copies, with only permissible private, birth-date, and witness-identifying information withheld.

https://illinoisfoia.org/opinions/letter-58746/ 2023-09-11T00:00:00Z

A requester asked for emails and records from community members about making up school days lost during a strike. The Illinois Attorney General's Public Access Bureau determined that the school district violated FOIA by improperly withholding the records under exemptions for collective bargaining matters. The decision found that the communications did not reveal aspects of the collective bargaining process and were not 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-58607/ 2023-05-25T00:00:00Z

A reporter requested police reports from the City of Joliet, but the City redacted portions of the records, citing several FOIA exemptions. The Illinois Attorney General's office reviewed the unredacted records and found that most redactions were proper, but two specific items—a business phone number and the name of a treating hospital—were not exempt. The office requested that the City provide the reporter with copies of the non-exempt portions of the narrative sections.

https://illinoisfoia.org/opinions/letter-71500/ 2023-03-17T00:00:00Z

A reporter sought e-mails from the mayor's personal account concerning public business, one of which the mayor's office redacted as containing personal information about a grieving crime victim's family. The PAC determined that while some of the redacted material was purely personal and properly withheld, other portions concerned potential actions the mayor's office might take and served a public interest that outweighed the family's privacy interest. The mayor's office was asked to release a le

https://illinoisfoia.org/opinions/letter-71207/ 2022-10-16T00:00:00Z

A resident requested police call records for their address, but the police department redacted certain names and dates of birth from the documents provided. The resident complained to the Attorney General's office, which reviewed the records and concluded that the police department correctly protected private information from public disclosure. The case is now closed with no further action required.

https://illinoisfoia.org/opinions/letter-68657/ 2022-09-27T00:00:00Z

This determination addressed whether the City of Chicago Department of Planning and Development properly redacted emails about a parking-lot sale under FOIA exemptions 7(1)(f) (deliberative process) and 7(1)(r) (real estate sale/negotiation records). The Public Access Bureau found the Department properly withheld most redacted material because it consisted of predecisional deliberations or information tied to ongoing negotiations for the sale of city-owned parcels, which remain exempt under 7(1)

https://illinoisfoia.org/opinions/2022-pac-71261/ 2022-07-25T00:00:00Z

The requester sought the application materials submitted by unsuccessful candidates for a vacant seat on a village board of trustees, which the village withheld, arguing the materials were not public records and were protected by personal privacy. The Public Access Counselor held that the applications were public records because the village president used them to fulfill his statutory duty to fill the vacancy, and that the public interest in knowing who sought the appointed office and their qual

https://illinoisfoia.org/opinions/letter-69508/ 2022-06-08T00:00:00Z

A person requested records of complaints and investigations regarding a specific public employee from the DeKalb County Housing Authority, but the Authority denied the request. The Illinois Attorney General's Public Access Bureau reviewed the case and concluded that the Authority did not prove by clear and convincing evidence that the records were entirely exempt from disclosure. The Authority must release the records, but may redact the complainant's name and other identifying information to pr

https://illinoisfoia.org/opinions/letter-70898/ 2022-05-04T00:00:00Z

A requester asked for disability claim records from the State Universities Retirement System (SURS) with personal information removed. SURS denied the request, stating the documents were medical records exempt from disclosure. The Attorney General's office agreed, noting that unlike some other types of private information, the law does not allow for the release of medical records even if they are de-identified.

https://illinoisfoia.org/opinions/letter-68242/ 2021-12-02T00:00:00Z

An individual requested unredacted RADAR reports and related records from Oakton Community College. The Illinois Attorney General's Public Access Bureau concluded that the college did not improperly withhold information, except for certain discrete details. The decision did not specify what those details were or order any specific release.

https://illinoisfoia.org/opinions/letter-56184/ 2021-07-01T00:00:00Z

A citizen requested police reports mentioning his name, but the police department denied the request, claiming various privacy and law enforcement exemptions. The Attorney General's office reviewed the records and concluded that the department was wrong to withhold the documents entirely, as they should have provided the records with appropriate redactions instead of a blanket denial.

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-65678/ 2020-12-29T00:00:00Z

The requester, a watchdog organization, sought police and incident reports about a man's arrest and death, which a police department withheld in full on the theory that disclosure could interfere with the pending prosecution of two other people arrested from the same vehicle. The Public Access Counselor held that FOIA requires disclosure of basic arrest information within 72 hours regardless of a pending case, and that the department's bare assertion of interference did not meet its burden to wi

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