https://illinoisfoia.org/exemptions/7-1-c/ 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/2026-pac-94563/ 2026-08-26T00:00:00Z

A reporter asked for emails between a former city official and a contractor. The city refused, saying the emails were private lawyer-client talks. The Attorney General said no, because the emails were with an outside person first, so they must be released.

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-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-90484/ 2026-01-13T00:00:00Z

ProPublica requested 911 audio recordings from the Lake County Sheriff's Office, which redacted the decedent's statements, citing privacy concerns for surviving family members. The Illinois Attorney General's Public Access Bureau reviewed the request and concluded that the Sheriff's Office improperly redacted the recording. The Bureau found that the Sheriff's Office failed to show that privacy interests outweighed the public interest in disclosure, distinguishing the case from precedent involvin

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/2025-pac-89024/ 2025-12-23T00:00:00Z

The requester, a journalist, sought police officer witness questionnaires used to identify potential Brady/Giglio disclosure obligations, which a county state's attorney's office redacted to remove the officers' names, arrest-history answers, and additional-information sections. The Public Access Counselor held that the redacted information bore directly on the officers' public duties, was purely factual rather than deliberative, and did not reflect legal advice or attorney work product. The off

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/letter-88619/ 2025-09-09T00:00:00Z

A requester asked Metra for the job applications and résumés of people who applied for positions but were not hired. Metra refused to release this information, arguing it would violate the privacy of those applicants. The Attorney General's office agreed with Metra, concluding that the privacy rights of unsuccessful job applicants generally outweigh the public's interest in seeing those documents.

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-84503/ 2025-06-06T00:00:00Z

A citizen requested a police report but was denied because they did not provide a photo ID to prove they were the victim involved in the incident. The Attorney General's office agreed with the police department, stating that the department acted reasonably in withholding the records until the requester's identity could be confirmed. To get the records, the requester must provide the requested identification.

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-86037/ 2025-04-21T00:00:00Z

A citizen requested a specific police report, but the Sheriff's Office refused to release it, arguing that doing so would violate the personal privacy of the people involved. The Attorney General's office reviewed the report and agreed that the privacy rights of the individuals mentioned in the report are more important than the public's right to see it. As a result, the Sheriff's Office is not required to release the document.

https://illinoisfoia.org/opinions/letter-85882/ 2025-04-03T00:00:00Z

A citizen asked a school district for their teacher interview questions regarding diversity, equity, and inclusion. The school district refused to release them, and the Attorney General's office agreed, stating that interview questions are considered 'examination data' that can be kept private to ensure a fair hiring process. This means the public does not have a right to access specific interview questions used by public employers.

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-84561/ 2025-01-27T00:00:00Z

A citizen asked the Illinois State Police for records related to license plate tracking and surveillance data. The police department stated they could not find any records, and the Attorney General's office agreed that the police performed a proper search and that any records they might have are legally protected from public release. This means the request was denied and the case is now closed.

https://illinoisfoia.org/opinions/letter-84296/ 2025-01-15T00:00:00Z

A citizen requested body-worn camera footage from the DuPage County Sheriff's Office, which denied the request. The Illinois Attorney General's Public Access Bureau reviewed the case and found the request unfounded. The Bureau concluded that because the requester was not present during the recording and did not interact with law enforcement, they were not a 'subject of the encounter' under the Law Enforcement Officer-Worn Body Camera Act, and the footage was not flagged for mandatory disclosure.

https://illinoisfoia.org/opinions/letter-82640/ 2024-12-31T00:00:00Z

A requester asked for I-Pass records related to a specific person, but the Lake County Forest Preserve District refused, claiming the records were exempt under several FOIA exemptions. The Attorney General's office reviewed the case and concluded that the District did not prove by clear and convincing evidence that the records were exempt under sections 7(1)(c), 7.5(w), 7(1)(d)(i), or 7(1)(d)(vi) of FOIA. The determination found that the District improperly denied the request.

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/2024-pac-83122/ 2024-12-27T00:00:00Z

The requester, a union counsel, sought a letter that current and former oversight agency employees had sent a city commission asking it to investigate the agency's chief administrator, which the commission withheld citing multiple exemptions including deliberative process, audit materials, and adjudication of disciplinary cases. The Public Access Counselor held that the commission failed to show the letter was predecisional deliberative material, an internal audit record, work created for law en

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/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/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/2024-pac-81170/ 2024-06-21T00:00:00Z

The requester, a fair housing organization, sought a dataset of scattered-site public housing units including their addresses and occupancy status, and the housing authority redacted most digits of the street numbers for vacant units, citing the exemption for vulnerability assessments and security plans. The Public Access Counselor held that street addresses are not themselves vulnerability assessments, security measures, or response plans, so the exemption did not apply on its face. The housing

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-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/24-006/ 2024-04-01T00:00:00Z

The requester, an investigative reporter, sought police reports concerning a man who went missing and was later found dead, which a sheriff's office withheld in full as an unwarranted invasion of privacy and, for one report, as interfering with a law enforcement proceeding. The Public Access Counselor held that the reports lacked graphic content warranting privacy protection given the substantial public interest in the case, and that the sheriff's office's law-enforcement-proceeding claims were

https://illinoisfoia.org/opinions/2023-pac-78717/ 2024-01-24T00:00:00Z

The requester sought invoices and documents underlying township payments to its law firm, and the township withheld a related settlement agreement based on a mutual nondisparagement clause it read as barring disclosure. The Public Access Counselor held that settlement agreements are expressly public records under FOIA and that a nondisparagement clause does not create an enforceable confidentiality obligation that can override that requirement. The township was directed to provide the requester

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-75330/ 2023-10-04T00:00:00Z

A citizen requested body camera footage from a police encounter, but the City of Bloomington blurred out much of the video, claiming privacy exemptions. The Attorney General's office reviewed the footage and decided the City went too far, as the video showed a public interaction that did not involve highly personal or private behavior. The City was told that it could not legally hide the identity of the person involved in that specific encounter.

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-73556/ 2023-07-31T00:00:00Z

A citizen requested financial records from the Hunt Lima Drainage District regarding maintenance taxes, but the District refused, citing privacy concerns. The Illinois Attorney General's Public Access Bureau reviewed the records and determined that the District improperly withheld the annual maintenance assessment rolls because they relate to public funds, not private personal income. However, the District may redact home addresses of individual property owners before releasing the records, and

https://illinoisfoia.org/opinions/letter-69899/ 2023-07-18T00:00:00Z

The requester sought e-mails between four specified individuals, which the state's attorney's office partially withheld to protect a former employee's name and negotiations with the public defender's office. The PAC determined that the employee's name bore on the performance of public duties and was improperly redacted, and that communications between the two adversarial offices did not qualify as deliberative or attorney-client material, though some information about mental-health records, vict

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/2023-pac-76309/ 2023-06-16T00:00:00Z

The requester, a television news producer, sought police records about a former teacher's arrest and prosecution for offenses against a student, which a police department withheld in full as an unwarranted invasion of the minor victim's privacy. The Public Access Counselor held that although the victim's privacy interest in graphic details was substantial, most of the records could be disclosed with the victim's identity and any explicit details redacted, given the significant public interest in

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-75440/ 2023-05-25T00:00:00Z

A requester asked the City of Chicago for a summary of proposals submitted for the 'LaSalle Street Reimagined' project. The City provided the document but blacked out parts of it, claiming they were exempt from public view. The Attorney General's office reviewed the request and decided the City did not prove the redactions were legal, ordering them to release the unredacted document.

https://illinoisfoia.org/opinions/letter-71689/ 2023-05-05T00:00:00Z

A reporter requested text messages between the Mayor and other officials. The City provided the messages but redacted parts they claimed were private. The Attorney General's office reviewed the messages and agreed that the redacted portions were personal in nature and not subject to FOIA disclosure.