7(1)(d)

FOIA

Law-enforcement/administrative-proceeding records

Law-enforcement/administrative-proceeding records (general)

Read the full statute text on /statutes →

Jump to the 60 issues decided under this provision, with a drafting brief ↓

1 upheld (no violation found) · 15 rejected (violation found) · 1 closed / insufficient info / other, out of 17 documents.

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

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

Section 7(1)(d) covers records connected to law-enforcement proceedings and administrative adjudications. In these matters, public bodies invoked it to withhold termination and resignation paperwork, police reports and narratives, dashboard and body-camera video, dispatch audio and 911 data, and investigative files, arguing disclosure would interfere with pending investigations or prosecutions, affect jury selection or a fair trial, or fall within disciplinary proceedings.

The Public Access Counselor generally applied the exemption narrowly in these decisions. With one exception allowing redaction of home or personal telephone numbers, the Counselor found withholding improper where the body offered only a general or speculative claim of interference without specific support. Reporters seeking employment-status communications, arrest reports, chase videos, and response-time data, among others, were held entitled to disclosure after the claimed law-enforcement or fair-trial basis was not substantiated.

At a glance: 17 documents from 2012 to 2026(16 binding opinions, 1 determination letter). Most often cited alongside: 7(1)(c) (Personal privacy) (9); 7(1)(b) (Private information) (8); 7(1)(a) (Confidential under other federal or State law) (4); 7(1)(f) (Preliminary drafts, notes, and deliberative materials) (3); 7(1)(n) (Employee grievance/discipline adjudication records) (2).

Recurring issues

Public bodies withheld employee termination or resignation paperwork on the ground it would interfere with a prosecution or proceeding. (A termination letter for a public employee, Resignation and termination paperwork for police officers)
Police withheld reports, narratives, videos and audio by asserting disclosure would interfere with a pending investigation or prosecution without specific support. (A police department's case/incident report and related records, Police arrest reports, A state police field report referenced in a crash report)
Public bodies claimed disclosure would deprive a person of a fair trial or taint jury selection. (A termination letter for a public employee, Dashcam footage, dispatch audio, and internal reviews of a fatal police chase, Redacted narrative sections of police arrest reports)
Bodies cited disciplinary or administrative adjudication and other related exemptions to withhold footage or internal records after an investigation. (Video surveillance footage from an animal control facility, A letter requesting a vote of no confidence)

Practical points

A public body should explain with specific facts how disclosure would interfere with a pending proceeding rather than relying on a general assertion.
A requester can challenge a broad withholding of police reports, video, or 911 records when no specific interference has been shown.
Redactions should be limited to the specific information shown to be exempt, such as home or personal telephone numbers in 911 recordings.

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

All 17 documents citing 7(1)(d)

Issues decided under 7(1)(d)

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

60 issues across 41 determination letters:35 violation found · 22 no violation · 3 no determination / resolved.

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

Authorities the Bureau cites most on this issue

Day v. City of Chicago, 388 Ill. App. 3d 70 (1st Dist. 2009) cited 11 times
Baudin v. City of Crystal Lake, 192 Ill. App. 3d 530, 536 (2d Dist. 1989) cited 11 times
Copley Press, Inc. v. City of Springfield cited 8 times
Chicago Alliance for Neighborhood Safety v. City of Chicago, 348 Ill. App. 3d 188 (1st Dist. 2004) cited 7 times
Southern Illinoisan v. Illinois Department of Public Health, 218 Ill. 2d 390, 844 N.E.2d 1 (2006) cited 5 times
A state police field report referenced in a crash report (Pub. Acc. Op. No. 17-001) cited 5 times
Lieber v. Board of Trustees of Southern Illinois University, 176 Ill. 2d 401, 407 (1997) cited 5 times
Washington Post Co. v. U.S. Dep't of Justice, 863 F.2d 96, 102 (D.C. Cir. 1988) cited 4 times

How to challenge a denial on this issue

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

When a challenge is strong

The public body's denial relies on conclusory statements or speculation without specific facts showing how disclosure would interfere with proceedings. The body must provide clear and convincing evidence with specific facts; bare assertions are insufficient.Based on: Audio and video recordings of a police photo ar… · Police body-camera footage of a traffic stop ar… · Police reports and video footage of a traffic c…
The records do not contain confidential source or witness information, yet the body withheld them under section 7(1)(d)(iv). The exemption only protects identities of persons who provided information to law enforcement; interactions with arrestees or general crime descriptions are not covered.Based on: Police body-camera footage of a traffic stop ar… · 2024 · A police report of a DUI arrest and vehicle imp… · Police records of a past burglary investigation
The public body claims the fair trial exemption but no trial or hearing is pending or imminent. Section 7(1)(d)(iii) requires a pending or truly imminent trial and a showing that disclosure would seriously interfere with fairness; speculation about future proceedings is insufficient.Based on: Police body-camera footage of a traffic stop ar… · Police interview records of a private citizen · An investigation of police officers
The records were not created in the course of an administrative enforcement proceeding, so the body's claim under section 7(1)(d)(ii) fails. The exemption applies only to records created in active administrative enforcement proceedings.Based on: Police body-camera footage of a traffic stop ar… · A letter about workplace harassment allegations
The public body claims unique investigative techniques but only describes routine procedures or fails to show how disclosure would reveal specialized techniques. Generalized descriptions do not meet the burden; the body must show the techniques are unique and disclosure would cause demonstrable harm.Based on: Police body-camera footage of a traffic stop ar… · An email about an incident log · Police use-of-force reports for 2017

When the public body usually wins

The public body redacts names, contact information, and other identifying details of witnesses or persons who provided information to law enforcement. Section 7(1)(d)(iv) protects the anonymity of such persons, and contact information is also exempt under other provisions.Based on: Investigative records and photos of a 1992 murd… · Police reports and complaints about an individu… · Police records of a past burglary investigation
The public body withholds records in their entirety because redaction cannot meaningfully protect a confidential source's identity. If disclosure would necessarily reveal the identity of a source, the entire record may be withheld.Based on: Police incident report of criminal damage to a … · Witness statements in a police report · Body-camera footage and 911 recordings of a YMC…
The public body demonstrates with specific facts that disclosure would interfere with an active, early-stage law enforcement investigation. When an investigation is ongoing and disclosure would reveal witness statements or suspect identities, the exemption applies.Based on: Video footage of a shooting under investigation · Police reports, body camera footage, and 911 re… · Police reports on a fatal motor vehicle accident
The public body withholds internal communications about enforcement strategy during an active administrative enforcement proceeding. Disclosure of internal deliberations on enforcement actions could interfere with the proceeding.Based on: Records on environmental and zoning violations …
The public body shows that disclosure would reveal specialized investigative techniques in a non-segregable manual. A law enforcement agency's audit manual containing non-segregable specialized techniques is exempt under section 7(1)(d)(v).Based on: Internal audit manual sections for tax enforcem…

Points to put in your letter

State that the denial is conclusory and lacks specific facts; demand that the public body provide clear and convincing evidence of how disclosure would interfere.Based on: Audio and video recordings of a police photo ar… · Police body-camera footage of a traffic stop ar… · Police reports and video footage of a traffic c…
Point out that the records do not contain confidential source information—for example, they only capture interactions between officers and the arrestee—so section 7(1)(d)(iv) does not apply.Based on: Police body-camera footage of a traffic stop ar… · 2024 · A police report of a DUI arrest and vehicle imp…
Argue that no trial or hearing is pending or imminent, and the public body has not shown a substantial likelihood of serious interference with fairness.Based on: Police body-camera footage of a traffic stop ar… · Police interview records of a private citizen · An investigation of police officers
Note that the records were not created in an administrative enforcement proceeding, so the (d)(ii) exemption is inapplicable.Based on: Police body-camera footage of a traffic stop ar… · A letter about workplace harassment allegations
Explain that the claimed investigative techniques are routine and not unique, and the public body has not demonstrated demonstrable harm from disclosure.Based on: Police body-camera footage of a traffic stop ar… · Police use-of-force reports for 2017

Common mistakes

A requester might assume that any denial under section 7(1)(d) is invalid without checking if the public body provided specific facts showing interference.Based on: Audio and video recordings of a police photo ar… · Police body-camera footage of a traffic stop ar…
A requester might not realize that witness names and identifying details are often properly redacted, and may demand full disclosure of all witness information.Based on: Investigative records and photos of a 1992 murd… · Police reports and complaints about an individu…
A records coordinator might mistakenly redact information that does not reveal a confidential source's identity, such as general crime descriptions or police handling details.Based on: Police records of a past burglary investigation
A records coordinator might think that citing the exemption number without a detailed rationale is sufficient to meet the burden of proof.Based on: Audio and video recordings of a police photo ar… · I-Pass transponder and license plate data for a…
A requester might fail to gather facts about whether a trial is actually pending before challenging a fair trial exemption, weakening their argument.Based on: Police body-camera footage of a traffic stop ar… · Police interview records of a private citizen

Facts to gather first

Whether a trial date has been set or any hearing is scheduled.
Whether the records contain witness statements or only interactions between law enforcement and the requester/arrestee.
Whether the public body's denial letter includes a detailed, fact-specific explanation or only boilerplate language.
Whether the records were created as part of an administrative enforcement proceeding (e.g., an active investigation by a regulatory agency).
Whether the investigative techniques claimed are described in public manuals, policies, or are common knowledge.

These notes are based on non-binding determination letters; outcomes depend on specific facts, and you should verify the current status of the law and the PDFs of the decisions.

Drafting brief for an AI assistant

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

TOPIC: 5 ILCS 140/7(1)(d) - Law-enforcement/administrative-proceeding records
SOURCE: Illinois Attorney General Public Access Bureau decisions compiled at https://illinoisfoia.org/exemptions/7-1-d/
NOTE: Determination letters are not binding precedent; they show how the Bureau applies the law. Verify every decision against the source PDF before citing it.

VIOLATION FOUND (35, 20 shown):
- Redaction under section 7(1)(d)(iv) for confidential source
  Rule: The driver's statements to police in response to questioning prior to arrest do not fall within the exemption for confidential sources or persons providing information to law enforcement.
  Decision: A police report of a DUI arrest and vehicle impoundment (non-binding determination letter, August 21, 2024) https://illinoisfoia.org/opinions/letter-82136/
- Withholding entire crash records under 7(1)(d)(i)
  Rule: A public body must show with specific facts, not conclusory statements, that disclosure would interfere with law enforcement proceedings.
  Decision: Police reports and video footage of a traffic crash (non-binding determination letter, February 11, 2025) https://illinoisfoia.org/opinions/letter-83921/
- Section 7(1)(d)(i) interference with law enforcement proceedings
  Rule: A public body must provide specific facts showing disclosure would interfere with pending or reasonably contemplated law enforcement proceedings; speculation is insufficient.
  Decision: Police body-camera footage of a traffic stop arrest (non-binding determination letter, March 20, 2025) https://illinoisfoia.org/opinions/letter-83308/
- Section 7(1)(d)(ii) interference with administrative enforcement proceedings
  Rule: The public body did not show active administrative enforcement proceedings or that the recordings were created in the course of such proceedings.
  Decision: Police body-camera footage of a traffic stop arrest (non-binding determination letter, March 20, 2025) https://illinoisfoia.org/opinions/letter-83308/
- Section 7(1)(d)(iii) fair trial or impartial hearing
  Rule: The public body must demonstrate a pending or imminent trial and that disclosure would more likely than not seriously interfere with fairness; it failed to do so.
  Decision: Police body-camera footage of a traffic stop arrest (non-binding determination letter, March 20, 2025) https://illinoisfoia.org/opinions/letter-83308/
- Section 7(1)(d)(iv) confidential source or witness information
  Rule: The recordings captured only interactions between law enforcement and the arrestee, so no witness information subject to redaction was present.
  Decision: Police body-camera footage of a traffic stop arrest (non-binding determination letter, March 20, 2025) https://illinoisfoia.org/opinions/letter-83308/
- Section 7(1)(d)(v) unique investigative techniques
  Rule: The public body did not show that release of the recordings would reveal unique or specialized investigative techniques.
  Decision: Police body-camera footage of a traffic stop arrest (non-binding determination letter, March 20, 2025) https://illinoisfoia.org/opinions/letter-83308/
- Section 7(1)(d)(vi) endanger life or physical safety
  Rule: The public body did not establish that releasing the recordings would endanger the life or physical safety of law enforcement personnel or any other person.
  Decision: Police body-camera footage of a traffic stop arrest (non-binding determination letter, March 20, 2025) https://illinoisfoia.org/opinions/letter-83308/
- Section 7(1)(d)(vii) obstruction of ongoing criminal investigation
  Rule: The public body did not illustrate with facts how disclosure would obstruct an ongoing criminal investigation; mere speculation is insufficient.
  Decision: Police body-camera footage of a traffic stop arrest (non-binding determination letter, March 20, 2025) https://illinoisfoia.org/opinions/letter-83308/
- Denial of incident report under section 7(1)(d)(i)
  Rule: A public body must provide specific facts showing how disclosure would interfere with pending law enforcement proceedings; conclusory statements are insufficient.
  Decision: An incident report about missing swan decoys (non-binding determination letter, October 9, 2024) https://illinoisfoia.org/opinions/letter-82717/
- Section 7(1)(d)(i) law enforcement proceedings exemption
  Rule: Conclusory assertions that disclosure would interfere with law enforcement proceedings are insufficient; the body must show actual interference.
  Decision: I-Pass transponder and license plate data for an individual (non-binding determination letter, December 31, 2024) https://illinoisfoia.org/opinions/letter-82640/
- Section 7(1)(d)(vi) endangerment exemption
  Rule: The body must identify and explain a reasonable threat of harm; conclusory claims of endangerment are insufficient.
  Decision: I-Pass transponder and license plate data for an individual (non-binding determination letter, December 31, 2024) https://illinoisfoia.org/opinions/letter-82640/
- Withholding cross-designated deputy names under 7(1)(d)(vi)
  Rule: A public body must show disclosure would endanger officers beyond inherent risks; speculation about surveillance exposure does not meet the clear and convincing burden.
  Decision: A list of cross-designated sheriff's deputies (non-binding determination letter, December 30, 2024) https://illinoisfoia.org/opinions/letter-81145/
- Denial under section 7(1)(d)(i) law enforcement exemption
  Rule: A public body must provide objective indicia and specific facts showing disclosure would interfere with pending or contemplated law enforcement proceedings; conclusory assertions are insufficient.
  Decision: Surveillance video footage of a shooting incident (non-binding determination letter, July 22, 2022) https://illinoisfoia.org/opinions/letter-80655/
- Denial under section 7(1)(d)(iii) fair trial exemption
  Rule: A public body must establish that a trial or adjudication is pending or truly imminent and that disclosure would more probably than not seriously interfere with fairness; conclusory statements are insufficient.
  Decision: Surveillance video footage of a shooting incident (non-binding determination letter, July 22, 2022) https://illinoisfoia.org/opinions/letter-80655/
- Withholding under section 7(1)(d)(i) law enforcement exemption
  Rule: A public body must show objective indicia that disclosure would interfere with pending or reasonably contemplated law enforcement proceedings; mere possibility of a new trial is too speculative.
  Decision: Police interview records of a private citizen (non-binding determination letter, March 1, 2024) https://illinoisfoia.org/opinions/letter-79596/
- Withholding under section 7(1)(d)(iii) fair trial exemption
  Rule: To withhold records, a public body must show a trial is pending or truly imminent and that disclosure would more probably than not seriously interfere with fairness; speculation about a new trial is insufficient.
  Decision: Police interview records of a private citizen (non-binding determination letter, March 1, 2024) https://illinoisfoia.org/opinions/letter-79596/
- Section 7(1)(d)(v) investigative techniques exemption
  Rule: The public body's generalized and conclusory explanation failed to show unique or specialized techniques or demonstrable harm from disclosure.
  Decision: An email about an incident log (non-binding determination letter, September 28, 2023) https://illinoisfoia.org/opinions/letter-70185/
- Withholding photo array and lineup report under section 7(1)(d)(v)
  Rule: Bare assertions without a detailed rationale do not satisfy a public body's burden to prove an exemption applies by clear and convincing evidence.
  Decision: Audio and video recordings of a police photo array (non-binding determination letter, December 2, 2025) https://illinoisfoia.org/opinions/letter-64491/
- Withholding narratives and video under 7(1)(d)(vii)
  Rule: A public body must provide specific facts showing disclosure would obstruct an ongoing criminal investigation; conclusory assertions are insufficient.
  Decision: Police reports and dash-camera footage of an arrest (non-binding determination letter, October 26, 2020) https://illinoisfoia.org/opinions/letter-61964/

NO VIOLATION (22, 20 shown):
- Redaction of law enforcement records under section 7(1)(d)(iv)
  Rule: A public body may redact witness statements and identifying information when disclosure would unavoidably identify persons who provided information to law enforcement.
  Decision: Police reports and dashcam footage in a custody dispute (non-binding determination letter, January 5, 2022) https://illinoisfoia.org/opinions/letter-68694/
- Redaction of identifying information of individuals who provided information
  Rule: The Department may redact names and identifying information of individuals who provided information to the Department.
  Decision: Police reports on juvenile suspects at a golf course (non-binding determination letter, August 24, 2021) https://illinoisfoia.org/opinions/letter-66759/
- Redaction of complainant identity and statements under 7(1)(d)(iv)
  Rule: Section 7(1)(d)(iv) permits withholding the identity of a person who provides information to law enforcement, and records may be withheld entirely if redaction cannot meaningfully protect identity.
  Decision: Witness statements in a police report (non-binding determination letter, February 14, 2025) https://illinoisfoia.org/opinions/letter-85113/
- Withholding witness-identifying information under law enforcement exemption
  Rule: Records may be withheld in their entirety if disclosure would necessarily reveal the identity of a source and redaction cannot meaningfully be accomplished.
  Decision: Police incident report of criminal damage to a vehicle (non-binding determination letter, June 6, 2025) https://illinoisfoia.org/opinions/letter-84503/
- Denial of video footage under section 7(1)(d)(i)
  Rule: Disclosure of video footage during an early stage of an active law enforcement investigation would interfere with pending proceedings, so the exemption applies.
  Decision: Video footage of a shooting under investigation (non-binding determination letter, December 20, 2024) https://illinoisfoia.org/opinions/letter-84370/
- Withholding witness statements pending accident reconstruction report
  Rule: Withholding witness statements that would interfere with the creation of an incomplete accident reconstruction report is proper under the law enforcement exemption.
  Decision: Police reports and video footage of a traffic crash (non-binding determination letter, February 11, 2025) https://illinoisfoia.org/opinions/letter-83921/
- Redaction of witness name and sentence under 7(1)(d)(iv)
  Rule: A public body may withhold a witness's name and a sentence that would unavoidably disclose the identity of a confidential source or person providing information to law enforcement.
  Decision: Redacted name and sentence in a police report (non-binding determination letter, October 21, 2024) https://illinoisfoia.org/opinions/letter-82571/
- Withholding case report under 7(1)(d)(i)
  Rule: A public body may withhold records if it shows with clear and convincing evidence that disclosure would interfere with pending law enforcement proceedings.
  Decision: Police reports, body camera footage, and 911 recordings of a shooting (non-binding determination letter, September 5, 2024) https://illinoisfoia.org/opinions/letter-82157/
- Redaction of confidential source identity under section 7(1)(d)(iv)
  Rule: Blurring an individual who provided information to police is permissible to avoid disclosing a confidential source's identity.
  Decision: Police body-camera footage of a public encounter (non-binding determination letter, October 4, 2023) https://illinoisfoia.org/opinions/letter-75330/
- Redaction of witness contact information
  Rule: Section 7(1)(d)(iv) requires disclosure of witness names only, not contact information, which is exempt under section 7(1)(b).
  Decision: Redacted witness information in a police crash report (non-binding determination letter, February 6, 2023) https://illinoisfoia.org/opinions/letter-74691/
- Redaction of body camera audio under section 7(1)(d)(iv)
  Rule: Information that would unavoidably disclose the identity of a confidential source who provided information to law enforcement is exempt from disclosure.
  Decision: Body-camera footage and 911 recordings of a YMCA incident (non-binding determination letter, February 6, 2023) https://illinoisfoia.org/opinions/letter-74512/
- Redaction of witness identities under section 7(1)(d)(iv)
  Rule: Section 7(1)(d)(iv) protects the anonymity of persons who provide information to law enforcement, and redaction of witness names and identifying details is proper.
  Decision: Investigative records and photos of a 1992 murder case (non-binding determination letter, November 21, 2024) https://illinoisfoia.org/opinions/letter-62344/
- Permissible redaction of other suspects and incidents
  Rule: The City may redact specific information about other suspects who have not been arrested and other incidents that have not resulted in arrests.
  Decision: Police incident report for case 2019-48357 (non-binding determination letter, March 11, 2020) https://illinoisfoia.org/opinions/letter-61099/
- Permissible redaction of non-arrested witness identities
  Rule: The City may redact information identifying witnesses who provided information to police but were not arrested.
  Decision: Police incident report for case 2019-48357 (non-binding determination letter, March 11, 2020) https://illinoisfoia.org/opinions/letter-61099/
- Redaction of identifying information of victim, witnesses, and third parties
  Rule: Section 7(1)(d)(iv) permits redaction of names, addresses, contact information, and other identifying information of individuals who provide information to law enforcement.
  Decision: Police reports and complaints about an individual (non-binding determination letter, May 25, 2023) https://illinoisfoia.org/opinions/letter-58607/
- Withholding witness statements and suspect identity under 7(1)(d)(vii)
  Rule: Withholding witness statements and suspect-identifying information was proper because disclosure could reasonably be expected to obstruct an ongoing criminal investigation.
  Decision: Police reports on a fatal motor vehicle accident (non-binding determination letter, October 2, 2023) https://illinoisfoia.org/opinions/letter-58605/
- Withholding internal enforcement emails under 7(1)(d)(ii)
  Rule: Disclosure of internal emails discussing the District's enforcement actions going forward could interfere with its active administrative enforcement proceeding, so they are exempt.
  Decision: Records on environmental and zoning violations at a freight site (non-binding determination letter, February 1, 2022) https://illinoisfoia.org/opinions/letter-58120/
- Redaction of identifying information of persons providing information under 7(1)(d)(iv)
  Rule: Identifying information of persons who provide information to police may be redacted to protect their anonymity.
  Decision: Police records of a past burglary investigation (non-binding determination letter, April 17, 2018) https://illinoisfoia.org/opinions/letter-51910/
- Withheld jail round records exempt under section 7(1)(d)(vi)
  Rule: Records revealing correctional officers' times and locations are exempt because disclosure could endanger their life or physical safety.
  Decision: Jail inspection reports and security-round logs (non-binding determination letter, November 21, 2017) https://illinoisfoia.org/opinions/letter-49142/
- Permissible redaction of witness identifying information
  Rule: The City may redact names and identifying information of witnesses who voluntarily provided information to law enforcement.
  Decision: Disciplinary records and citizen complaints for three police officers (non-binding determination letter, February 11, 2016) https://illinoisfoia.org/opinions/letter-39260/

NO DETERMINATION / RESOLVED (3):
- Future denial under law enforcement and administrative exemptions
  Rule: Whether CPD can prove by clear and convincing evidence that disclosure would interfere with pending proceedings is undecided until a future request is denied.
  Decision: Police body-camera footage of a search warrant execution (non-binding determination letter, January 10, 2020) https://illinoisfoia.org/opinions/letter-60599/
- Permissible redaction of witness-identifying information
  Rule: Information identifying witnesses who provided information may be withheld from disclosure.
  Decision: An investigation of police officers (non-binding determination letter, June 27, 2018) https://illinoisfoia.org/opinions/letter-52348/
- Withholding records under section 7(1)(d)(i)
  Rule: Because the section 7(1)(f) determination was dispositive, the Public Access Bureau declined to address the applicability of section 7(1)(d)(i).
  Decision: Correspondence between state attorneys general on environmental policy (non-binding determination letter, August 24, 2016) https://illinoisfoia.org/opinions/letter-42018/

MOST-CITED AUTHORITIES: Day v. City of Chicago, 388 Ill. App. 3d 70 (1st Dist. 2009); Baudin v. City of Crystal Lake, 192 Ill. App. 3d 530, 536 (2d Dist. 1989); Copley Press, Inc. v. City of Springfield; Chicago Alliance for Neighborhood Safety v. City of Chicago, 348 Ill. App. 3d 188 (1st Dist. 2004); Southern Illinoisan v. Illinois Department of Public Health, 218 Ill. 2d 390, 844 N.E.2d 1 (2006); Ill. Att'y Gen. Pub. Acc. Op. No. 17-001

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

Violation found (35)

Redaction under section 7(1)(d)(iv) for confidential source
Rule: The driver's statements to police in response to questioning prior to arrest do not fall within the exemption for confidential sources or persons providing information to law enforcement.
Violation found A police report of a DUI arrest and vehicle impoundment · August 21, 2024
Withholding entire crash records under 7(1)(d)(i)
Rule: A public body must show with specific facts, not conclusory statements, that disclosure would interfere with law enforcement proceedings.
Violation found Police reports and video footage of a traffic crash · February 11, 2025
Section 7(1)(d)(i) interference with law enforcement proceedings
Rule: A public body must provide specific facts showing disclosure would interfere with pending or reasonably contemplated law enforcement proceedings; speculation is insufficient.
Violation found Police body-camera footage of a traffic stop arrest · March 20, 2025
Section 7(1)(d)(ii) interference with administrative enforcement proceedings
Rule: The public body did not show active administrative enforcement proceedings or that the recordings were created in the course of such proceedings.
Violation found Police body-camera footage of a traffic stop arrest · March 20, 2025
Section 7(1)(d)(iii) fair trial or impartial hearing
Rule: The public body must demonstrate a pending or imminent trial and that disclosure would more likely than not seriously interfere with fairness; it failed to do so.
Violation found Police body-camera footage of a traffic stop arrest · March 20, 2025
Section 7(1)(d)(iv) confidential source or witness information
Rule: The recordings captured only interactions between law enforcement and the arrestee, so no witness information subject to redaction was present.
Violation found Police body-camera footage of a traffic stop arrest · March 20, 2025
Section 7(1)(d)(v) unique investigative techniques
Rule: The public body did not show that release of the recordings would reveal unique or specialized investigative techniques.
Violation found Police body-camera footage of a traffic stop arrest · March 20, 2025
Section 7(1)(d)(vi) endanger life or physical safety
Rule: The public body did not establish that releasing the recordings would endanger the life or physical safety of law enforcement personnel or any other person.
Violation found Police body-camera footage of a traffic stop arrest · March 20, 2025
Section 7(1)(d)(vii) obstruction of ongoing criminal investigation
Rule: The public body did not illustrate with facts how disclosure would obstruct an ongoing criminal investigation; mere speculation is insufficient.
Violation found Police body-camera footage of a traffic stop arrest · March 20, 2025
Denial of incident report under section 7(1)(d)(i)
Rule: A public body must provide specific facts showing how disclosure would interfere with pending law enforcement proceedings; conclusory statements are insufficient.
Violation found An incident report about missing swan decoys · October 9, 2024
Section 7(1)(d)(i) law enforcement proceedings exemption
Rule: Conclusory assertions that disclosure would interfere with law enforcement proceedings are insufficient; the body must show actual interference.
Violation found I-Pass transponder and license plate data for an individual · December 31, 2024
Section 7(1)(d)(vi) endangerment exemption
Rule: The body must identify and explain a reasonable threat of harm; conclusory claims of endangerment are insufficient.
Violation found I-Pass transponder and license plate data for an individual · December 31, 2024
Withholding cross-designated deputy names under 7(1)(d)(vi)
Rule: A public body must show disclosure would endanger officers beyond inherent risks; speculation about surveillance exposure does not meet the clear and convincing burden.
Violation found A list of cross-designated sheriff's deputies · December 30, 2024
Denial under section 7(1)(d)(i) law enforcement exemption
Rule: A public body must provide objective indicia and specific facts showing disclosure would interfere with pending or contemplated law enforcement proceedings; conclusory assertions are insufficient.
Violation found Surveillance video footage of a shooting incident · July 22, 2022
Denial under section 7(1)(d)(iii) fair trial exemption
Rule: A public body must establish that a trial or adjudication is pending or truly imminent and that disclosure would more probably than not seriously interfere with fairness; conclusory statements are insufficient.
Violation found Surveillance video footage of a shooting incident · July 22, 2022
Withholding under section 7(1)(d)(i) law enforcement exemption
Rule: A public body must show objective indicia that disclosure would interfere with pending or reasonably contemplated law enforcement proceedings; mere possibility of a new trial is too speculative.
Violation found Police interview records of a private citizen · March 1, 2024
Withholding under section 7(1)(d)(iii) fair trial exemption
Rule: To withhold records, a public body must show a trial is pending or truly imminent and that disclosure would more probably than not seriously interfere with fairness; speculation about a new trial is insufficient.
Violation found Police interview records of a private citizen · March 1, 2024
Section 7(1)(d)(v) investigative techniques exemption
Rule: The public body's generalized and conclusory explanation failed to show unique or specialized techniques or demonstrable harm from disclosure.
Violation found An email about an incident log · September 28, 2023
Withholding photo array and lineup report under section 7(1)(d)(v)
Rule: Bare assertions without a detailed rationale do not satisfy a public body's burden to prove an exemption applies by clear and convincing evidence.
Violation found Audio and video recordings of a police photo array · December 2, 2025
Withholding narratives and video under 7(1)(d)(vii)
Rule: A public body must provide specific facts showing disclosure would obstruct an ongoing criminal investigation; conclusory assertions are insufficient.
Violation found Police reports and dash-camera footage of an arrest · October 26, 2020
Withholding of remaining incident report under section 7(1)(d)(i)
Rule: The City failed to show by clear and convincing evidence that disclosing information about arrestees and their incidents would interfere with pending law enforcement proceedings.
Violation found Police incident report for case 2019-48357 · March 11, 2020
Withholding remaining records under 7(1)(d)(vii)
Rule: The Police Department's largely conclusory explanation failed to demonstrate by clear and convincing evidence that disclosure of the remaining information would obstruct its ongoing criminal investigation.
Violation found Police reports on a fatal motor vehicle accident · October 2, 2023
Withholding external enforcement emails under 7(1)(d)(ii)
Rule: Emails that merely relay facts about alleged violations without describing internal actions or opinions do not meet the public body's clear and convincing burden of showing interference.
Violation found Records on environmental and zoning violations at a freight site · February 1, 2022
Section 7(1)(d)(i) law enforcement exemption
Rule: A public body must show by clear and convincing evidence how disclosure would interfere with a pending investigation; conclusory assertions are insufficient.
Violation found Death investigation records and police-federal communications · June 5, 2023
Withholding police reports in entirety under 7(1)(d)(vi)
Rule: A public body must specifically explain how disclosure would endanger life or physical safety; conclusory assertions are insufficient to meet its burden.
Violation found Police reports naming the requester · July 1, 2021
Section 7(1)(d)(ii) exemption claim rejected
Rule: IDOT failed to meet its burden of showing the responsive letter was exempt under section 7(1)(d)(ii) because the record was not created in the course of an administrative enforcement proceeding.
Violation found A letter about workplace harassment allegations · February 28, 2022
Section 7(1)(d)(iii) exemption claim rejected
Rule: IDOT failed to meet its burden of showing the responsive letter was exempt under section 7(1)(d)(iii) because the record was not created in the course of an administrative enforcement proceeding.
Violation found A letter about workplace harassment allegations · February 28, 2022
Section 7(1)(d)(iv) exemption claim rejected
Rule: IDOT failed to meet its burden of showing the responsive letter was exempt under section 7(1)(d)(iv) because the record was not created in the course of an administrative enforcement proceeding.
Violation found A letter about workplace harassment allegations · February 28, 2022
Section 7(1)(d)(v) law enforcement techniques
Rule: Use of force reports do not disclose unique or specialized investigative techniques, so the exemption does not apply.
Violation found Police use-of-force reports for 2017 · September 13, 2018
Section 7(1)(d)(iii) fair trial exemption denial
Rule: A public body must show a pending or imminent trial and that disclosure would more probably than not seriously interfere with fairness; an ongoing investigation alone is insufficient.
Violation found An investigation of police officers · June 27, 2018
Redaction of police handling, crime nature, and surveillance descriptions under 7(1)(d)(iv)
Rule: Information about police handling, general crime nature, and surveillance images does not reveal a confidential source's identity and is not exempt.
Violation found Police records of a past burglary investigation · April 17, 2018
Withholding records in their entireties under section 7(1)(d)(iii)
Rule: A public body must show that a trial is imminent and that disclosure would more probably than not seriously interfere with its fairness; conclusory claims are insufficient.
Violation found Police reports and 9-1-1 recordings in a retail theft and homicide case · December 6, 2017
Withholding records in their entireties under sections 7(1)(d)(i) and 7(1)(d)(vii)
Rule: A public body must provide a detailed, specific justification showing how disclosure would obstruct an ongoing investigation or interfere with pending proceedings; generalized concerns are insufficient.
Violation found Police reports and 9-1-1 recordings in a retail theft and homicide case · December 6, 2017
Redaction of names under administrative enforcement exemption
Rule: Records not created in administrative enforcement proceedings or held by law enforcement for law enforcement purposes are not exempt.
Violation found Animal research protocol and medical records · July 14, 2015
Section 7(1)(d)(i) withholding based on pending law enforcement proceedings
Rule: Section 7(1)(d)(i) applies only to proceedings conducted by the recipient law enforcement agency, and the Sheriff's Office neither conducts the trial court proceedings nor showed interference with its own proceedings.
Violation found Dash-cam video and police reports of a fatal pursuit · March 31, 2015

No violation (22)

Redaction of law enforcement records under section 7(1)(d)(iv)
Rule: A public body may redact witness statements and identifying information when disclosure would unavoidably identify persons who provided information to law enforcement.
No violation Police reports and dashcam footage in a custody dispute · January 5, 2022
Redaction of identifying information of individuals who provided information
Rule: The Department may redact names and identifying information of individuals who provided information to the Department.
No violation Police reports on juvenile suspects at a golf course · August 24, 2021
Redaction of complainant identity and statements under 7(1)(d)(iv)
Rule: Section 7(1)(d)(iv) permits withholding the identity of a person who provides information to law enforcement, and records may be withheld entirely if redaction cannot meaningfully protect identity.
No violation Witness statements in a police report · February 14, 2025
Withholding witness-identifying information under law enforcement exemption
Rule: Records may be withheld in their entirety if disclosure would necessarily reveal the identity of a source and redaction cannot meaningfully be accomplished.
No violation Police incident report of criminal damage to a vehicle · June 6, 2025
Denial of video footage under section 7(1)(d)(i)
Rule: Disclosure of video footage during an early stage of an active law enforcement investigation would interfere with pending proceedings, so the exemption applies.
No violation Video footage of a shooting under investigation · December 20, 2024
Withholding witness statements pending accident reconstruction report
Rule: Withholding witness statements that would interfere with the creation of an incomplete accident reconstruction report is proper under the law enforcement exemption.
No violation Police reports and video footage of a traffic crash · February 11, 2025
Redaction of witness name and sentence under 7(1)(d)(iv)
Rule: A public body may withhold a witness's name and a sentence that would unavoidably disclose the identity of a confidential source or person providing information to law enforcement.
No violation Redacted name and sentence in a police report · October 21, 2024
Withholding case report under 7(1)(d)(i)
Rule: A public body may withhold records if it shows with clear and convincing evidence that disclosure would interfere with pending law enforcement proceedings.
No violation Police reports, body camera footage, and 911 recordings of a shooting · September 5, 2024
Redaction of confidential source identity under section 7(1)(d)(iv)
Rule: Blurring an individual who provided information to police is permissible to avoid disclosing a confidential source's identity.
No violation Police body-camera footage of a public encounter · October 4, 2023
Redaction of witness contact information
Rule: Section 7(1)(d)(iv) requires disclosure of witness names only, not contact information, which is exempt under section 7(1)(b).
No violation Redacted witness information in a police crash report · February 6, 2023
Redaction of body camera audio under section 7(1)(d)(iv)
Rule: Information that would unavoidably disclose the identity of a confidential source who provided information to law enforcement is exempt from disclosure.
No violation Body-camera footage and 911 recordings of a YMCA incident · February 6, 2023
Redaction of witness identities under section 7(1)(d)(iv)
Rule: Section 7(1)(d)(iv) protects the anonymity of persons who provide information to law enforcement, and redaction of witness names and identifying details is proper.
No violation Investigative records and photos of a 1992 murder case · November 21, 2024
Permissible redaction of other suspects and incidents
Rule: The City may redact specific information about other suspects who have not been arrested and other incidents that have not resulted in arrests.
No violation Police incident report for case 2019-48357 · March 11, 2020
Permissible redaction of non-arrested witness identities
Rule: The City may redact information identifying witnesses who provided information to police but were not arrested.
No violation Police incident report for case 2019-48357 · March 11, 2020
Redaction of identifying information of victim, witnesses, and third parties
Rule: Section 7(1)(d)(iv) permits redaction of names, addresses, contact information, and other identifying information of individuals who provide information to law enforcement.
No violation Police reports and complaints about an individual · May 25, 2023
Withholding witness statements and suspect identity under 7(1)(d)(vii)
Rule: Withholding witness statements and suspect-identifying information was proper because disclosure could reasonably be expected to obstruct an ongoing criminal investigation.
No violation Police reports on a fatal motor vehicle accident · October 2, 2023
Withholding internal enforcement emails under 7(1)(d)(ii)
Rule: Disclosure of internal emails discussing the District's enforcement actions going forward could interfere with its active administrative enforcement proceeding, so they are exempt.
No violation Records on environmental and zoning violations at a freight site · February 1, 2022
Redaction of identifying information of persons providing information under 7(1)(d)(iv)
Rule: Identifying information of persons who provide information to police may be redacted to protect their anonymity.
No violation Police records of a past burglary investigation · April 17, 2018
Withheld jail round records exempt under section 7(1)(d)(vi)
Rule: Records revealing correctional officers' times and locations are exempt because disclosure could endanger their life or physical safety.
No violation Jail inspection reports and security-round logs · November 21, 2017
Permissible redaction of witness identifying information
Rule: The City may redact names and identifying information of witnesses who voluntarily provided information to law enforcement.
No violation Disciplinary records and citizen complaints for three police officers · February 11, 2016
Withholding videos under fair trial exemption
Rule: Withholding was proper because disclosure at the time of the request would have created a substantial likelihood of depriving a person of a fair trial.
No violation Police video of a hit-and-run incident · March 29, 2019
Section 7(1)(d)(v) exemption for Audit Manual
Rule: The Department is a law enforcement agency; the Audit Manual contains non-segregable specialized investigative techniques whose disclosure would demonstrably harm the Department.
No violation Internal audit manual sections for tax enforcement · October 30, 2018

No determination / resolved (3)

Future denial under law enforcement and administrative exemptions
Rule: Whether CPD can prove by clear and convincing evidence that disclosure would interfere with pending proceedings is undecided until a future request is denied.
No determination / resolved Police body-camera footage of a search warrant execution · January 10, 2020
Permissible redaction of witness-identifying information
Rule: Information identifying witnesses who provided information may be withheld from disclosure.
No determination / resolved An investigation of police officers · June 27, 2018
Withholding records under section 7(1)(d)(i)
Rule: Because the section 7(1)(f) determination was dispositive, the Public Access Bureau declined to address the applicability of section 7(1)(d)(i).
No determination / resolved Correspondence between state attorneys general on environmental policy · August 24, 2016