https://illinoisfoia.org/exemptions/7-1-d/ 2026-06-09T00:00:00Z 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/2025-pac-85063/ 2025-03-28T00:00:00Z

The requester, a newspaper reporter, sought resignation and termination paperwork for police officers, which a police department withheld citing law-enforcement-proceeding, fair-trial, and police-training-database exemptions. The Public Access Counselor held that the department's conclusory assertions did not establish that any pending or contemplated proceeding would be interfered with, that a trial was imminent, or that the records were confidential Board-held data rather than the department's

https://illinoisfoia.org/opinions/letter-83308/ 2025-03-20T00:00:00Z

A citizen requested police body camera footage of a specific traffic stop and arrest. The Village of Oak Brook provided the video but redacted parts of it, claiming it would interfere with legal proceedings. The Attorney General's office reviewed the footage and decided the Village did not provide enough evidence to justify the redactions, ordering them to release the unredacted video.

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/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/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/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/2024-pac-79729/ 2024-03-15T00:00:00Z

The requester sought video footage of an incident at a county animal control facility, which a sheriff's office withheld, first suggesting the investigation would soon close and then, on a renewed request, as records of an employee disciplinary adjudication. The Public Access Counselor held that the footage was investigatory material predating and existing independently of any adjudication, so the sheriff's office failed to prove the adjudication exemption applied. The sheriff's office was direc

https://illinoisfoia.org/opinions/21-012/ 2021-12-16T00:00:00Z

The requester, a newspaper reporter, sought 911 call response-time data, which a city emergency-communications office withheld, arguing that revealing how quickly units arrived on scene could help criminals evade police or target vulnerable areas. The Public Access Counselor held that response-time data are factual records of employee performance rather than vulnerability assessments or security plans, and that the office's claims of danger were speculative rather than clear and convincing. The

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-62350/ 2020-07-07T00:00:00Z

The requester, a newspaper reporter, sought squad car video, dispatch audio, and a written critique concerning a fatal police chase, which a sheriff's office withheld on the ground that disclosure could taint the jury pool in a related pending civil wrongful-death lawsuit. The Public Access Counselor held that the sheriff's office's assertion was conclusory and failed to explain with specific facts how disclosure of records -- most of which did not even depict the crash, and a critique containin

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

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

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

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

https://illinoisfoia.org/opinions/2017-pac-47695/ 2017-08-14T00:00:00Z

The requester, a radio reporter, sought two 9-1-1 call recordings connected to a widely reported child's death, and the sheriff's office withheld both as containing exempt biometric identifiers and withheld one further as likely to interfere with its active investigation. The Public Access Counselor held that an ordinary voice recording is not a "biometric identifier" absent some measurement or analysis of the voice itself, and that the sheriff's office's conclusory assertion of investigative in

https://illinoisfoia.org/opinions/2017-pac-45894/ 2017-03-14T00:00:00Z

The requester sought a copy of a specific field report, and the state police agency withheld it in full, asserting that disclosure would interfere with a pending or contemplated law-enforcement proceeding. The Public Access Counselor held that a bare assertion that an investigation remains open, without any factual explanation of how disclosure would interfere with a proceeding, does not meet the agency's burden under that exemption. The state police agency was directed to disclose the field rep

https://illinoisfoia.org/opinions/2011-pac-17813/ 2012-04-02T00:00:00Z

The requester sought a state licensing agency's complete investigative file on a real estate licensee, after the agency had previously been directed, in response to an earlier related request, to release the same file for failing to prove it was exempt, but did not comply. The agency again refused to respond to the new request, refused to provide the Public Access Counselor with copies of the records for review, and continued to assert without adequate support that the file was exempt as an inve