https://illinoisfoia.org/exemptions/7-1-m/ 2025-12-23T00:00:00Z https://illinoisfoia.org/opinions/2025-pac-89024/ 2025-12-23T00:00:00Z

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

https://illinoisfoia.org/opinions/letter-86152/ 2025-09-17T00:00:00Z

A school-district employee requested legal-fee invoices related to Title IX matters. The PAC found that the redactions were narrowly tailored to confidential attorney-client communications and that the district met its burden under section 7(1)(m); generic billing information already disclosed was not at issue. The matter was closed.

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/2025-pac-85693/ 2025-06-18T00:00:00Z

The requester sought records showing an $87,500 city payment toward a settlement in a lawsuit against a named alderman, which a city department withheld in part as an attorney-client communication not subject to discovery. The Public Access Counselor held that the record was a settlement document signed by the alderman and a city attorney rather than a confidential communication seeking or giving legal advice, and that records showing the use of public funds are subject to FOIA and the state con

https://illinoisfoia.org/opinions/letter-86063/ 2025-04-22T00:00:00Z

A citizen requested business licensing and enforcement records from the City of Centralia, but the City partially denied the request, citing exemptions for private information, attorney-client communications, and examination data. The citizen challenged the partial denial, arguing the search was insufficient and the exemptions were misapplied. The Public Access Bureau of the Illinois Attorney General reviewed the records and concluded that the City conducted a reasonable search and properly appl

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/letter-82252/ 2025-02-14T00:00:00Z

A citizen requested a risk assessment report regarding stable buildings from the Palatine Park District, but the District refused to release it. The Attorney General's office reviewed the document and agreed that it is exempt from disclosure under state law. Consequently, the District was not required to provide the record.

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-82484/ 2024-12-04T00:00:00Z

A resident requested financial records and audit-related documents from the Village of Orland Park. The Village denied access to some of these records, claiming they were exempt under section 7(1)(m) of FOIA, which covers communications with auditors and internal audits. The Attorney General's office found that the Village did not provide enough evidence to prove the records were actually exempt and instructed them to provide the requested information.

https://illinoisfoia.org/opinions/letter-81203/ 2024-10-16T00:00:00Z

A requester sought a law firm's investigative report on sexual-harassment allegations against a district employee, which the school district withheld and refused to give the PAC for confidential review, citing a risk of waiving attorney-client privilege. The PAC held that providing records for its confidential review does not waive the privilege, and that the district's refusal to do so violated FOIA's cooperation requirement, but separately determined, based on the district's affidavit, that th

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-66688/ 2024-06-18T00:00:00Z

A reporter requested police records, which the City of Joliet provided with redactions, claiming the information was protected by attorney-client privilege. The Attorney General's office reviewed the records and found that the redacted parts were merely factual status updates, not legal advice. Consequently, the City was asked to release the unredacted information to the reporter.

https://illinoisfoia.org/opinions/letter-80023/ 2024-06-06T00:00:00Z

A citizen requested emails from a Village, but the Village withheld some of them, claiming they were protected by legal and insurance-related exemptions. The Attorney General's office reviewed the records and agreed that the Village was legally allowed to keep those specific emails private. As a result, the case is closed with no further action required.

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-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/letter-73336/ 2022-10-19T00:00:00Z

The question was whether a public body properly denied a FOIA request as an unduly burdensome repeated request under 5 ILCS 140/3(g) where the request came from one of three individuals who routinely share and coordinate FOIA requests and responses. The Public Access Bureau held that the Request for Review was unfounded, concluding that the requester and two other individuals acted collectively as a 'group' and therefore qualified as a single 'person' under 5 ILCS 140/2(b), so the public body wa

https://illinoisfoia.org/opinions/2021-pac-c-0536/ 2022-01-31T00:00:00Z

The requester, a newspaper reporter, sought reports a state's attorney gave county board members about an employee's alleged misuse of county funds for personal education expenses, which the state's attorney's office withheld as protected by the attorney-client privilege. The Public Access Counselor's confidential review confirmed that the withheld record reflected genuine legal advice to the county board rather than public-relations strategy, so the privilege applied. The denial was upheld and

https://illinoisfoia.org/opinions/letter-66131/ 2021-04-30T00:00:00Z

A citizen requested records of payments the City of Centralia made to a law firm. The City provided the records but blacked out names of clients and attorneys, claiming legal privilege. The Attorney General's office found these redactions were improper and requested that the City provide the unredacted documents.

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/letter-56112/ 2019-04-08T00:00:00Z

A resident requested records from the Village of Waterman and was charged a copying fee, which he disputed. The Illinois Attorney General's Public Access Bureau concluded that the Village did not improperly charge the fee and did not improperly redact records. The Village also proposed furnishing redacted copies of previously withheld records, and the Bureau found those proposed redactions permissible.

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-52748/ 2018-10-17T00:00:00Z

A resident requested emails between Wesley Township and its law firm, but the Township refused to release them, claiming they were protected by attorney-client privilege. The Attorney General's office reviewed the request and found that the Township did not provide enough proof to justify keeping the emails secret. Consequently, the Township was asked to release the emails to the requester.

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-44377/ 2017-02-01T00:00:00Z

A journalist requested nine categories of investment records from a public pension investment board, three of which he sought review of after the board denied or redacted them. The PAC found the board's refusal to answer a vague question about a specific investment did not violate FOIA, but that most of the board's trade-secret and privacy redactions to a consultant's report were improper given the report had already been shared at an open meeting, and that a private accounting firm's audit repo

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-36450/ 2015-11-23T00:00:00Z

The requester sought e-mails between a state's attorney's office investigator and a school district official concerning an investigation into the district's finances, which the office withheld as deliberative material and attorney work product. The PAC determined the e-mails merely requested and furnished factual information and did not reflect any deliberative process, legal theories, or litigation strategy, so neither exemption applied. The state's attorney's office was asked to provide the e-

https://illinoisfoia.org/opinions/2015-pac-35747/ 2015-09-22T00:00:00Z

The requester, a journalist, sought the governor's daily appointment calendar showing meetings and attendees, and the governor's office redacted the names of meeting attendees, arguing the calendar was a personal scheduling tool and that disclosure would reveal deliberative and privileged legal strategy. The Public Access Counselor held that because the calendar was maintained by staff, used to facilitate scheduling, and accessible to senior officials, it was a public record documenting the offi

https://illinoisfoia.org/opinions/2014-pac-27500/ 2014-04-15T00:00:00Z

The requester sought copies of a law firm's legal billing invoices from the city government for the past calendar year, but the city withheld them entirely, citing exemptions for attorney-client privileged communications, collective bargaining matters, and (later) records related to employee disciplinary adjudications. The Illinois Attorney General's Public Access Bureau held that the city violated FOIA by withholding the invoices in full, finding that only specific descriptive entries revealing

https://illinoisfoia.org/opinions/2012-pac-18205/ 2012-03-12T00:00:00Z

The requester sought copies of legal invoices reflecting a school district's expenses in several lawsuits, and the school district withheld the invoices in full, asserting attorney-client privilege. The Public Access Counselor held that while some invoice descriptions could reveal privileged communications and could be redacted, generic descriptions of the work performed, attorneys' initials, time spent, and billed amounts are not privileged and must be disclosed. The school district was directe