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  <title>Illinois FOIA &amp; OMA Reference: 7(1)(d)(iv)</title>
  <link href="https://illinoisfoia.org/exemptions/7-1-d-iv/feed.xml" rel="self"/>
  <link href="https://illinoisfoia.org/exemptions/7-1-d-iv/"/>
  <id>https://illinoisfoia.org/exemptions/7-1-d-iv/</id>
  <updated>2025-02-14T00:00:00Z</updated>
  <entry>
    <title>Northfield Police Department properly withheld complainant's statement under 7(1)(c) and 7(1)(d)(iv)</title>
    <link href="https://illinoisfoia.org/opinions/letter-85113/"/>
    <id>https://illinoisfoia.org/opinions/letter-85113/</id>
    <updated>2025-02-14T00:00:00Z</updated>
    <summary>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 </summary>
  </entry>
  <entry>
    <title>Village of Glenview improperly withheld police report in its entirety</title>
    <link href="https://illinoisfoia.org/opinions/letter-77465/"/>
    <id>https://illinoisfoia.org/opinions/letter-77465/</id>
    <updated>2024-12-30T00:00:00Z</updated>
    <summary>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</summary>
  </entry>
  <entry>
    <title>Village of Bartlett properly redacted witness-identifying info from police report under 7(1)(d)(iv)</title>
    <link href="https://illinoisfoia.org/opinions/letter-82571/"/>
    <id>https://illinoisfoia.org/opinions/letter-82571/</id>
    <updated>2024-10-21T00:00:00Z</updated>
    <summary>A citizen requested a police report from the Village of Bartlett, but the Village redacted certain information. The citizen asked the Attorney General's office to review the redactions. The PAC concluded that the Village acted legally because the redacted information could identify witnesses or confidential sources, which is protected under state law.</summary>
  </entry>
  <entry>
    <title>Village of Libertyville properly withheld police reports under section 7(1)(c) personal privacy exemption</title>
    <link href="https://illinoisfoia.org/opinions/letter-83212/"/>
    <id>https://illinoisfoia.org/opinions/letter-83212/</id>
    <updated>2024-10-02T00:00:00Z</updated>
    <summary>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</summary>
  </entry>
  <entry>
    <title>Illinois State Police properly withheld jail surveillance footage under 7(1)(e)</title>
    <link href="https://illinoisfoia.org/opinions/letter-81194/"/>
    <id>https://illinoisfoia.org/opinions/letter-81194/</id>
    <updated>2024-09-23T00:00:00Z</updated>
    <summary>A requester asked the Illinois State Police for jail surveillance videos following a death in custody. The police provided some footage but withheld other parts, arguing that releasing them would compromise jail security. The Attorney General's office agreed with the police, concluding that the withheld videos could reveal security vulnerabilities like blind spots.</summary>
  </entry>
  <entry>
    <title>Alton Police Department properly withheld case report under 7(1)(d)(i), must offer narrowing for remaining records</title>
    <link href="https://illinoisfoia.org/opinions/letter-82157/"/>
    <id>https://illinoisfoia.org/opinions/letter-82157/</id>
    <updated>2024-09-05T00:00:00Z</updated>
    <summary>A requester sought police records about a shooting. The PAC found that the police department properly withheld the main case report because disclosure would interfere with an ongoing investigation, but determined that the department had not established a basis to withhold the remaining records in their entirety. The department should issue a revised response explaining any undue burden and offering the requester an opportunity to narrow the request.</summary>
  </entry>
  <entry>
    <title>Hawthorn Woods Police Department improperly redacted parts of a DUI arrest report</title>
    <link href="https://illinoisfoia.org/opinions/letter-82136/"/>
    <id>https://illinoisfoia.org/opinions/letter-82136/</id>
    <updated>2024-08-21T00:00:00Z</updated>
    <summary>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 </summary>
  </entry>
  <entry>
    <title>City of Joliet FOIA partial violation for redacting phone number and hospital name</title>
    <link href="https://illinoisfoia.org/opinions/letter-58607/"/>
    <id>https://illinoisfoia.org/opinions/letter-58607/</id>
    <updated>2023-05-25T00:00:00Z</updated>
    <summary>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.</summary>
  </entry>
  <entry>
    <title>City of Bloomington did not violate FOIA by redacting body camera audio</title>
    <link href="https://illinoisfoia.org/opinions/letter-74512/"/>
    <id>https://illinoisfoia.org/opinions/letter-74512/</id>
    <updated>2023-02-06T00:00:00Z</updated>
    <summary>A citizen requested body camera footage from a police incident at a YMCA, but the City redacted parts of the audio. The Attorney General's office reviewed the request and found that the City was legally allowed to hide those portions to protect the privacy of the people speaking to the police. This means the City followed the law and does not have to release the redacted audio.</summary>
  </entry>
  <entry>
    <title>Rantoul Police Department properly redacted witness contact info and birth dates from crash report</title>
    <link href="https://illinoisfoia.org/opinions/letter-74691/"/>
    <id>https://illinoisfoia.org/opinions/letter-74691/</id>
    <updated>2023-02-06T00:00:00Z</updated>
    <summary>A requester asked the Rantoul Police Department for a crash report, but the Department redacted witness contact information and birth dates. The Illinois Attorney General's Public Access Bureau found that the Department did not violate FOIA by redacting that information, because FOIA only requires disclosure of witness names, and the other details are exempt. The Bureau also noted that the Department redacted descriptive information (like height and eye color) and requested that the Department f</summary>
  </entry>
  <entry>
    <title>IDOT improperly withheld harassment letter under FOIA 7(1)(d) enforcement proceeding exemptions</title>
    <link href="https://illinoisfoia.org/opinions/letter-56109/"/>
    <id>https://illinoisfoia.org/opinions/letter-56109/</id>
    <updated>2022-02-28T00:00:00Z</updated>
    <summary>A citizen requested a letter from the Illinois Department of Transportation (IDOT) regarding workplace harassment allegations. IDOT refused to release the letter, claiming it was part of an ongoing legal or enforcement process. The Attorney General's office reviewed the request and decided that the letter was not part of an enforcement proceeding, meaning IDOT must release it to the requester.</summary>
  </entry>
  <entry>
    <title>Rock Island Police Department properly redacted witness identities under 7(1)(d)(iv)</title>
    <link href="https://illinoisfoia.org/opinions/letter-68694/"/>
    <id>https://illinoisfoia.org/opinions/letter-68694/</id>
    <updated>2022-01-05T00:00:00Z</updated>
    <summary>Under FOIA, section 7(1)(d)(iv) allows a public body to withhold information that would reveal the identity of a complainant, victim, or witness. Here, the Department redacted portions of the records that would identify which involved party provided specific information. The PAC found that because disclosing the redacted statements and corresponding names would reveal the source of the information, the Department properly applied this exemption. The PAC also noted that it was unnecessary to revi</summary>
  </entry>
  <entry>
    <title>Sandwich Police Department improperly withheld incident report under 7.5(bb) for juvenile suspects</title>
    <link href="https://illinoisfoia.org/opinions/letter-66759/"/>
    <id>https://illinoisfoia.org/opinions/letter-66759/</id>
    <updated>2021-08-24T00:00:00Z</updated>
    <summary>Under FOIA, a public body must disclose records unless a specific exemption applies. Here, the Department claimed the entire report was exempt under section 7.5(bb) because it involved juvenile suspects. However, the PAC reasoned that the exemption only protects information that is prohibited from disclosure by the Juvenile Court Act, which does not categorically exempt all records involving juveniles. The decisive fact was that the incident report contained information that could be disclosed a</summary>
  </entry>
  <entry>
    <title>City of Waukegan improperly withheld incident report under active investigation exemptions</title>
    <link href="https://illinoisfoia.org/opinions/letter-61099/"/>
    <id>https://illinoisfoia.org/opinions/letter-61099/</id>
    <updated>2020-03-11T00:00:00Z</updated>
    <summary>A law firm requested a police incident report from the City of Waukegan, but the City refused to provide it, claiming it was part of an active investigation. The Attorney General's office reviewed the request and found that the City was wrong to withhold the entire document. The City was asked to release the non-exempt portions of the report.</summary>
  </entry>
  <entry>
    <title>Chicago Police Department improperly redacted burglary case records under FOIA exemptions</title>
    <link href="https://illinoisfoia.org/opinions/letter-51910/"/>
    <id>https://illinoisfoia.org/opinions/letter-51910/</id>
    <updated>2018-04-17T00:00:00Z</updated>
    <summary>The requester sought police reports concerning an old break-in, which the department produced with extensive redactions under FOIA's private-information, personal-privacy, and law-enforcement-source exemptions. The PAC determined that redactions of individuals' private identifying information, a partial license plate, victim and uninvolved-party identities, and information that would reveal confidential sources were proper, but that redactions of business contact information, ages, uninvolved bu</summary>
  </entry>
  <entry>
    <title>Village of Skokie improperly withheld police records and 9-1-1 recordings under 7(1)(b) etc</title>
    <link href="https://illinoisfoia.org/opinions/letter-48891/"/>
    <id>https://illinoisfoia.org/opinions/letter-48891/</id>
    <updated>2017-12-06T00:00:00Z</updated>
    <summary>A reporter requested police records and 9-1-1 calls related to a high-profile crime, but the Village of Skokie denied the request entirely, citing exemptions under the Freedom of Information Act. The Illinois Attorney General's Public Access Bureau reviewed the case and concluded that the Village did not meet its burden to prove by clear and convincing evidence that the records were exempt from disclosure. The Bureau determined that the Village improperly denied the requested records in their en</summary>
  </entry>
  <entry>
    <title>City of Chicago Department of Law improperly withheld factual email under 7(1)(m)</title>
    <link href="https://illinoisfoia.org/opinions/letter-39684/"/>
    <id>https://illinoisfoia.org/opinions/letter-39684/</id>
    <updated>2016-04-08T00:00:00Z</updated>
    <summary>This determination addresses whether the City of Chicago Department of Law properly withheld the text of an email between two of its attorneys under FOIA's section 7(1)(m) exemption for attorney-client privileged communications and attorney work product. The Public Access Bureau held that the Department improperly withheld the email, finding it did not meet its burden of showing either privilege applied. The email was a purely factual status update on two legal matters that disclosed no litigati</summary>
  </entry>
  <entry>
    <title>Duty to Provide &quot;Clear and Convincing&quot; Evidence to Support Assertion of Exemptions; Possibility of Obtaining Public Records through Discovery Does Not Preclude FOIA Requests</title>
    <link href="https://illinoisfoia.org/opinions/2013-pac-25483/"/>
    <id>https://illinoisfoia.org/opinions/2013-pac-25483/</id>
    <updated>2013-11-12T00:00:00Z</updated>
    <summary>The requester asked the police department for a copy of a specific police report, but the department denied the request, claiming disclosure would interfere with law enforcement proceedings and could deprive someone of a fair trial. The department also argued the requester should instead obtain the report through court discovery procedures. The PAC held that the department's justifications were vague and conclusory, failing to show by clear and convincing evidence that either exemption applied, </summary>
  </entry>
  <entry>
    <title>Records Relating to a Public Body's Internal Investigation into an Employee's Conduct</title>
    <link href="https://illinoisfoia.org/opinions/2013-pac-23559/"/>
    <id>https://illinoisfoia.org/opinions/2013-pac-23559/</id>
    <updated>2013-06-11T00:00:00Z</updated>
    <summary>The requester, a journalist, sought police and internal-investigation records concerning an off-duty car accident involving a police department's assistant chief, and the city government withheld the underlying investigative materials, arguing they related to an &quot;adjudication&quot; of a disciplinary case and were therefore exempt. The Public Access Counselor held that an informal internal inquiry that never proceeded to a formal adjudicatory hearing does not qualify as an &quot;adjudication&quot; under the nar</summary>
  </entry>
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