https://illinoisfoia.org/exemptions/7-1-f/ 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-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/2025-pac-86098/ 2025-07-15T00:00:00Z

The requester, a reporter, sought an attachment to a school board president's email forwarding a former law firm's correspondence to board members, which a school district withheld citing attorney-client, deliberative-process, and other exemptions. The Public Access Counselor held that the record did not reflect legal advice sought from or given by the district's former attorney, did not represent the district's own predecisional deliberations, and was not otherwise shown to be legally confident

https://illinoisfoia.org/opinions/letter-85453/ 2025-06-13T00:00:00Z

A researcher requested applications for a state tax incentive program, but the DCEO refused to release them, claiming they were still under review and part of a deliberative process. The Attorney General's office disagreed, ruling that the records are public and must be released. The agency is allowed to redact specific private financial or commercial data before providing the documents.

https://illinoisfoia.org/opinions/letter-85045/ 2025-03-26T00:00:00Z

A journalist requested communications and a legal memo from the City of Chicago's Department of Planning and Development. The City provided records but redacted parts under exemptions for internal drafts (section 7(1)(f)) and attorney-client privilege (section 7(1)(m)). The Illinois Attorney General's Public Access Bureau reviewed the unredacted records and determined that the redactions under section 7(1)(f) were proper for the specific emails discussed, which concerned pending FOIA requests an

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-83737/ 2024-12-23T00:00:00Z

A requester asked for communications and copies of advertisements related to a public safety sales tax. The County provided some records but withheld draft versions of advertisements, claiming they were preliminary and part of the decision-making process. The Attorney General's office agreed that these drafts were exempt from disclosure because they reflect the County's internal deliberative process.

https://illinoisfoia.org/opinions/2024-pac-83650/ 2024-12-18T00:00:00Z

The requester, a reporter, sought a county state's attorney's policies on police-involved shootings and in-custody deaths and all related reports issued since 2019, and the office first claimed no responsive records existed before belatedly disclosing one report and then refusing to search further, citing undue burden. The Public Access Counselor held that the office failed to demonstrate it had conducted a reasonable search and had not met the procedural prerequisites, including conferring with

https://illinoisfoia.org/opinions/letter-80318/ 2024-11-22T00:00:00Z

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

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

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

https://illinoisfoia.org/opinions/letter-83108/ 2024-11-19T00:00:00Z

The requester sought e-mails between the county transportation division and its roadwork contractor, one of which the division redacted as deliberative material. The PAC determined the e-mail reflected negotiation between the division and a contractor protecting its own interests, not an internal deliberation, so the deliberative-process exemption did not apply. The division was asked to provide the requester with an unredacted copy of the e-mail.

https://illinoisfoia.org/opinions/letter-81969/ 2024-08-02T00:00:00Z

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

https://illinoisfoia.org/opinions/letter-79727/ 2024-07-26T00:00:00Z

A citizen requested records from the Matteson Police Department regarding his own background check and employment history. The Department refused to release the documents, claiming they were part of an internal deliberative process. The Attorney General's office agreed with the Department, finding that the records were protected because they reflected the internal decision-making process used to evaluate the requester's job application.

https://illinoisfoia.org/opinions/letter-81880/ 2024-07-01T00:00:00Z

A company requested emails from a state office regarding a cancelled bid, but the office denied the request. When the company asked the Attorney General's office to review the denial, the PAC determined it could not help because the request was for a commercial purpose. Under Illinois law, the PAC does not have the authority to resolve disputes over commercial FOIA requests.

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-69962/ 2024-05-15T00:00:00Z

A job applicant requested her own background check and polygraph results from the Romeoville Police Department, but the department refused to release them. The Attorney General's office reviewed the records and found that the police department failed to prove that all the withheld information was legally exempt. The department was asked to release the non-exempt portions of the records.

https://illinoisfoia.org/opinions/letter-76974/ 2024-02-13T00:00:00Z

A reporter requested documents from the Cook County Pension Fund, but the Fund blacked out certain parts of a real estate plan. The Attorney General's office reviewed the request and decided the Fund was legally allowed to keep those parts private. This means the requester will not receive the redacted information.

https://illinoisfoia.org/opinions/letter-56946/ 2023-12-11T00:00:00Z

A requester asked for records from the City of Chicago's Legislative Reference Bureau, but the Bureau denied the request without listing the name and title of the person who made the decision. The Attorney General's office agreed that this violated the law, which requires public bodies to identify the specific person responsible for a denial. The case was closed because the PAC determined a formal binding opinion was not necessary.

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-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-71500/ 2023-03-17T00:00:00Z

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

https://illinoisfoia.org/opinions/letter-71954/ 2023-03-17T00:00:00Z

The ACLU requested records from the City of Chicago regarding vehicle ticketing and impoundment policies. The City refused to release parts of a 'Bench Book' used by administrative judges, claiming it was exempt from disclosure. The Attorney General's office reviewed the document and decided the City did not provide a valid legal reason to keep it secret, ordering the City to release the records.

https://illinoisfoia.org/opinions/2022-pac-73915/ 2023-01-26T00:00:00Z

The requester, a faculty member joined by several colleagues, sought the raw written responses to an employee engagement survey, which a state academy provided in aggregate but withheld the free-response answers as predecisional and deliberative. The Public Access Counselor held that the academy sustained its burden that the withheld comments were used in the president's evaluation of a principal and that disclosure could chill candor in future staff surveys. The academy's partial denial was uph

https://illinoisfoia.org/opinions/letter-70212/ 2022-10-13T00:00:00Z

A reporter requested a presentation about the City's response to civil unrest, but the City blacked out large portions of the document claiming they were exempt from disclosure. The Attorney General's office reviewed the slides and found that the City did not have a valid legal reason to hide most of that information. The City was asked to release the majority of the slides to the reporter.

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

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

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

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

https://illinoisfoia.org/opinions/letter-69562/ 2022-03-23T00:00:00Z

A reporter requested text messages from the Mayor of Chicago, but the City blacked out parts of the messages claiming they were private or not related to public business. The Attorney General's office reviewed the records and decided that most of the redacted information was properly withheld, but that the City must release some specific parts that were improperly withheld. The City is now required to provide a revised response to the reporter.

https://illinoisfoia.org/opinions/2022-pac-69424/ 2022-03-11T00:00:00Z

The requester, a newspaper reporter, sought a retiring police chief's farewell email to department staff, which a village withheld and then largely redacted, arguing it was a personal communication rather than a public record. The Public Access Counselor held that because the email commented on department policy, procedure, and staff conduct, it was a public record pertaining to public business rather than private affairs, and that its content bore on the chief's public duties so was not exempt

https://illinoisfoia.org/opinions/letter-65404/ 2021-09-09T00:00:00Z

A citizen requested a consultant's study about the local fire department, but the Village refused to release it, claiming the study was exempt as a preliminary draft. The Attorney General's office agreed with the Village, finding that both the draft and final versions of the study were exempt under section 7(1)(f) of FOIA because they were part of the Village's deliberative process and had not been publicly cited by the head of the public body. This means the public does not have an immediate ri

https://illinoisfoia.org/opinions/2021-pac-66968/ 2021-05-24T00:00:00Z

The requester, a nearby resident, sought communications between a city and a funeral home concerning the funeral home's pending zoning application, which the city withheld as predecisional and deliberative. The Public Access Counselor held that the deliberative-process exemption protects only inter- and intra-agency communications, not communications with a third party such as the funeral home that has its own independent interest in the zoning outcome. The city was directed to disclose the with

https://illinoisfoia.org/opinions/letter-61760/ 2020-08-31T00:00:00Z

A requester asked the City of Peoria for records regarding misconduct complaints against two employees. The City withheld some information, claiming it was private or exempt, but the Attorney General's office found that some of those redactions were improper and requested the City release the specific portions of the documents.

https://illinoisfoia.org/opinions/2019-pac-56867/ 2019-05-29T00:00:00Z

The requester sought a copy of a police department's monthly extradition-unit staffing calendar, which the department withheld as predecisional and deliberative draft material. The Public Access Counselor held that the calendar was purely factual -- a listing of officers and their assigned duties for each day -- and that the department failed to show how its disclosure would reveal the give-and-take of any internal deliberation. The department was directed to disclose the calendar.

https://illinoisfoia.org/opinions/letter-53659/ 2019-02-07T00:00:00Z

A requester sought emails from a school district concerning classroom observations and integration. The PAC found that emails withheld under section 7(1)(f) were properly protected as predecisional, deliberative communications, but that the district did not establish that other emails concerning potential collective bargaining were exempt under section 7(1)(p). The district was asked to provide those records, subject to any permissible redactions.

https://illinoisfoia.org/opinions/letter-53007/ 2019-02-01T00:00:00Z

A reporter requested records from the University of Illinois regarding an investigation into a professor's research. The University redacted or withheld portions of the records, citing exemptions under state and federal law. The Illinois Attorney General's Public Access Bureau concluded that the University improperly denied portions of the records responsive to the requests.

https://illinoisfoia.org/opinions/letter-49942/ 2018-10-30T00:00:00Z

A requester asked the Illinois Department of Natural Resources for records about the gating of Griffith Cave from 2013 to 2014. The Department provided some records but withheld others, and offered the requester a chance to view certain withheld information if he signed a Data License Agreement. The Public Access Bureau found that the Department did not meet its burden to justify withholding records under sections 7.5(aa) and 7(1)(i) of FOIA, and noted that FOIA does not allow a public body to d

https://illinoisfoia.org/opinions/letter-53887/ 2018-09-13T00:00:00Z

A reporter requested use of force reports from the Quincy Police Department, which initially provided a summary and then denied the full request citing privacy exemptions. The Attorney General's office determined that the Department improperly withheld the reports, except for certain discrete information. The Department may redact home addresses and signatures as private information under FOIA, and may also redact identifying details of non-arrested subjects to avoid an unwarranted invasion of p

https://illinoisfoia.org/opinions/letter-34218/ 2018-07-19T00:00:00Z

A citizen requested a budget document that was presented during a public fire district meeting. The district refused to release it, claiming it was a 'preliminary draft' that might confuse the public. The Attorney General's office disagreed, ruling that the district did not provide enough evidence to justify keeping the document secret and ordered them to release it.

https://illinoisfoia.org/opinions/2017-pac-49999/ 2018-01-23T00:00:00Z

The requester, a radio reporter, sought an unredacted copy of a departing village president's resignation email, and the village withheld several lines of the email, first citing the deliberative-process exemption and later also an exemption for employee-grievance adjudications. The Public Access Counselor held that the redacted text reflected the president's own final, already-made decision to resign rather than an ongoing predecisional deliberation, and that nothing indicated the email related

https://illinoisfoia.org/opinions/2017-pac-49564/ 2017-11-07T00:00:00Z

The requester, a newspaper reporter, sought audio recordings of the housing authority board's open meetings from a given year, and the housing authority withheld them as preliminary, deliberative material. The Public Access Counselor held that a verbatim recording of a meeting that was open to the public is inherently subject to public scrutiny and is not the kind of predecisional record the deliberative-process exemption protects, regardless of the purpose for which the recording was made. The

https://illinoisfoia.org/opinions/2017-pac-46589/ 2017-06-12T00:00:00Z

The requester sought raw traffic-count data collected during roadway monitoring, and the village withheld its entire preliminary traffic study as predecisional and deliberative. The Public Access Counselor held that purely factual data, such as vehicle counts, is not exempt as deliberative material unless it is inextricably intertwined with a public body's decision-making process, and the village had not shown that the counts revealed anything about its reasoning. The village was directed to dis

https://illinoisfoia.org/opinions/2017-pac-46587/ 2017-06-12T00:00:00Z

The requester, a wire-service reporter, sought records showing the job titles, locations, and numbers of employees the department deems essential during a pay interruption, and the department denied the request without acknowledging whether responsive records existed, first asserting attorney-client and deliberative-process exemptions and then withdrawing and reasserting different grounds. The Public Access Counselor held that a denial must state whether records exist and provide a detailed fact

https://illinoisfoia.org/opinions/letter-26247/ 2017-02-21T00:00:00Z

The Physicians Committee for Responsible Medicine requested records from the Southern Illinois University School of Medicine about animal use in medical training. The school withheld some emails, claiming they were internal drafts or deliberative communications. The Attorney General's office agreed that the school followed the law and was allowed to keep those specific documents private.

https://illinoisfoia.org/opinions/letter-42018/ 2016-08-24T00:00:00Z

Two legal groups, the Energy & Environment Legal Institute and the Free Market Environmental Law Clinic, jointly requested emails and correspondence between the Illinois and New York Attorney General offices. The Public Access Bureau (PAC) reviewed the request and concluded that the Illinois Attorney General's Office conducted a reasonable search for the records and did not improperly withhold records that it asserted were exempt under FOIA.

https://illinoisfoia.org/opinions/letter-38873/ 2016-06-30T00:00:00Z

The requester sought emails between the school district superintendent and a high school principal, and between the district and a parent, concerning complaints about morning announcements, which the district withheld under the deliberative-process and personal-privacy exemptions. The PAC determined that most Superintendent-Principal emails were properly withheld as predecisional, but two reflecting a final decision were not, and that the parent's emails were not inter- or intra-agency communica

https://illinoisfoia.org/opinions/letter-39705/ 2016-05-12T00:00:00Z

A reporter requested an employee survey from the Village of Oak Park, but the Village refused to release it, claiming it was part of their internal decision-making process. The Attorney General's office reviewed the request and agreed with the Village, ruling that the document was exempt from disclosure because it was used for internal policy formulation. This means the public does not have a right to access this specific type of internal survey.

https://illinoisfoia.org/opinions/letter-39684/ 2016-04-08T00:00:00Z

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

https://illinoisfoia.org/opinions/letter-36017/ 2016-03-31T00:00:00Z

The requester sought correspondence between the governor's office and a former state agency director, portions of which the office withheld as deliberative material, attorney-client communications, and personal information. The PAC determined that most of the pre-decisional emails and the personal emails were properly withheld, but that certain factual records and a legal-matter update did not qualify as deliberative or privileged and were improperly withheld. The governor's office was asked to

https://illinoisfoia.org/opinions/letter-37067/ 2016-02-26T00:00:00Z

The requester sought communications the department's personnel office received regarding hiring and staffing matters, which the department withheld as deliberative material. The PAC determined that the records largely requested and conveyed factual and logistical information rather than opinions or recommendations, so the department did not meet its burden of showing they were exempt as deliberative. The department was asked to furnish the records to the requester.

https://illinoisfoia.org/opinions/letter-37306/ 2016-01-04T00:00:00Z

A reporter requested budget-related documents from the Governor's budget office, but the office refused to release a PowerPoint presentation, claiming it was part of internal policy discussions. The Attorney General's office reviewed the request and found that the budget office did not prove the document was exempt from public view. Consequently, the office was asked to release the PowerPoint to the reporter.

https://illinoisfoia.org/opinions/2015-pac-37506/ 2015-12-29T00:00:00Z

The requester, a labor union representative, sought records concerning services provided by an outside budget consultant to a state budget agency, and the agency withheld a PowerPoint presentation the consultant had used to train agency budget analysts, arguing it reflected predecisional deliberations about the state budget. The Public Access Counselor held that the presentation was not exempt because it consisted of finalized policy guidance and general principles given to analysts as training