https://illinoisfoia.org/ 2026-09-30T00:00:00Z https://illinoisfoia.org/opinions/2026-pac-95139/ 2026-09-30T00:00:00Z

A public body must prove by clear and convincing evidence that an exemption applies, and exemptions are read narrowly. The sheriff's office denied a request for incident reports about restraint-chair use at the jail in its entirety under the private-information exemption (7(1)(b)) and the personal-privacy exemption (7(1)(c)), then added 7(1)(b-5), which covers law enforcement databases specifically designed to inform officers of a person's physical or mental status. The PAC held that discrete it

https://illinoisfoia.org/cases/2026%20IL%20App%20(3d)%20250200-U/ 2026-09-15T00:00:00Z

FOIA is mentioned only as the method defense counsel used to obtain Department investigative files, not as a claim decided by the court.

https://illinoisfoia.org/cases/2026%20IL%20App%20(1st)%20250575-U/ 2026-09-09T00:00:00Z

The circuit court's decision to deny plaintiff's request for civil penalties under section 11(j) of the Freedom of Information Act is reversed and the cause is remanded. The court's finding that defendant's violation of FOIA was deliberate and by design was sufficient to impose civil penalties under section 11(j).

https://illinoisfoia.org/opinions/2026-pac-94563/ 2026-08-26T00:00:00Z

A reporter asked for emails between a former city official and a contractor. The city refused, saying the emails were private lawyer-client talks. The Attorney General said no, because the emails were with an outside person first, so they must be released.

https://illinoisfoia.org/cases/2026%20IL%20App%20(5th)%20250237-U/ 2026-08-24T00:00:00Z

Inmate Cleother Tidwell requested the names and staffing roster of medical personnel at Pinckneyville Correctional Center under FOIA. IDOC denied the request under Section 7(1)(e-6), which exempts staff rosters, personnel-file records, and staffing assignment information requested by persons committed to IDOC, and the circuit court dismissed his complaint with prejudice as frivolous. The Fifth District affirmed, holding the requested records were clearly exempt and that Tidwell forfeited any cha

https://illinoisfoia.org/opinions/2026-pac-94532/ 2026-08-21T00:00:00Z

A citizen asked the City of Chicago for maps showing where storm drains and catch basins are located. The City refused, and the Attorney General's office agreed, saying that releasing this information could help criminals target infrastructure and endanger public safety. This means the City can keep those specific records secret.

https://illinoisfoia.org/cases/2026%20IL%20App%20(5th)%20250498-U/ 2026-08-18T00:00:00Z

Tidwell submitted a FOIA request to the City of Alton for the court docket in a lawsuit naming the City as a defendant. The City denied the request because it did not possess the court file and directed him to the Madison County court system. The Fifth District affirmed dismissal under section 2-619(a)(9), holding FOIA requires production only of records in the public body's possession and does not require a body to obtain records it does not maintain. The court also deemed the appeal frivolous

https://illinoisfoia.org/cases/2026%20IL%20App%20(4th)%20251109-U/ 2026-08-13T00:00:00Z

Inmate Marshall King requested racial profiling records for an officer from the Livingston County Sheriff's Office, which responded the records had to be sought from Pontiac Police. The trial court found no FOIA violation because the requested records did not exist and were not in the Sheriff's possession, and denied penalties. The Fourth District affirmed, presuming the dismissal was correct on the incomplete record and finding no willful violation to support civil penalties.

https://illinoisfoia.org/cases/2026%20IL%20App%20(5th)%20250810-U/ 2026-08-07T00:00:00Z

Plaintiffs challenged management of Cypress Creek Hill Nature Preserve and alleged FOIA violations for untimely responses, withheld communications, and redaction of threatened and endangered species names under section 7(1)(i). The Fifth District affirmed dismissal with prejudice, holding plaintiffs lacked standing for counts I, III, and IV concerning preserve master plans. It held count V failed to state a FOIA claim because the complaint and attached exhibits did not plead specific records req

https://illinoisfoia.org/cases/2026%20IL%20App%20(5th)%20241003-U/ 2026-08-07T00:00:00Z

FOIA is mentioned only as background to plaintiffs' continuing-violation tolling argument in an employment-termination dismissal case, not as a decided FOIA claim.

https://illinoisfoia.org/cases/2026%20IL%20App%20(1st)%20250641-U/ 2026-08-07T00:00:00Z

FOIA was cited only to distinguish Hart v. Illinois State Police, with the court expressly holding FOIA and public access were not at issue in this FOID restoration case.

https://illinoisfoia.org/cases/2026%20IL%20App%20(5th)%20241000-U/ 2026-08-07T00:00:00Z

The Open Meetings Act is mentioned only to describe a prior suit against Madison County; the present dismissal turns solely on improper claim-splitting.

https://illinoisfoia.org/cases/2026%20IL%20App%20(5th)%20241001-U/ 2026-08-07T00:00:00Z

The prior OMA suit over April 2020 executive sessions is discussed only as background to affirm dismissal of the successive suit for improper claim-splitting.

https://illinoisfoia.org/opinions/letter-90482/ 2026-07-31T00:00:00Z

Under OMA, a public body must conduct all final actions in an open meeting. The decisive fact here was that a majority of Board members signed a letter expressing support and responding to concerns, and then sent it to the administration—this constituted a final decision made privately, not during a properly noticed open meeting. The reasoning is that even though the members did not physically gather, their coordinated signing and sending of the letter outside a meeting effectively decided the m

https://illinoisfoia.org/opinions/2026-pac-94082/ 2026-07-28T00:00:00Z

Mr. Kilbane asked the Village for meeting agendas and minutes, but the Village never replied. The Attorney General's office said this was a violation of FOIA because public bodies must respond to requests within the law's time limits. The Village must now provide the records or properly deny the requests.

https://illinoisfoia.org/opinions/letter-91704/ 2026-07-21T00:00:00Z

Section 7.5(cc) of FOIA exempts officer-worn body camera recordings except to the extent the Law Enforcement Officer-Worn Body Camera Act allows disclosure. Under that Act, recordings generally may be released only if they are flagged for statutory reasons such as use of force or an arrest, or to a person the Act authorizes, and here the requester was not depicted in or the subject of the recordings and the footage was not flagged. The PAC concluded the police department properly withheld the fo

https://illinoisfoia.org/opinions/2026-pac-94008/ 2026-07-20T00:00:00Z

A local newspaper complained that the township board voted to create five new jobs without putting that item on the public meeting agenda. The Attorney General agreed that this was a violation of the Open Meetings Act because the agenda didn't mention the job creation, but found the board did properly explain what it was voting on before the vote. As a result, the board must be more careful to include such items on future agendas, but the action itself was not invalidated due to the recital.

https://illinoisfoia.org/opinions/2026-pac-93299/ 2026-06-30T00:00:00Z

A reporter asked the Oak Lawn Police Department for records about a specific arrest. The police refused to provide them, and the Attorney General's office reviewed the case, concluding that the police violated the Freedom of Information Act by not releasing the records. This means the police must now provide the requested documents.

https://illinoisfoia.org/opinions/letter-94590/ 2026-06-30T00:00:00Z

Under section 3(j), a public body that reasonably believes a request was not submitted by a person may require the requester to verify personhood 'orally or in writing.' The request for review was premature because the village had demanded verification but had not yet denied the request, so the PAC closed the matter without a finding. It nonetheless advised that the choice of method belongs to the requester, reasoning that letting a public body insist on oral verification would make it harder to

https://illinoisfoia.org/cases/2026%20IL%20App%20(1st)%20250205/ 2026-06-30T00:00:00Z

The appellate court reversed the circuit court's denial of civil penalties under FOIA, finding that the Chicago Police Department's justifications for its significant delay in responding to the records request were insufficient. The case was remanded for the circuit court to determine the appropriate amount of civil penalties to be assessed against the Department.

https://illinoisfoia.org/cases/2026%20IL%20App%20(1st)%20251564-U/ 2026-06-22T00:00:00Z

Plaintiff filed two OMA requests for review with the PAC alleging the Chicago Park District Board violated the Open Meetings Act, which the PAC did not decide for over two years despite a 60-day directive. After plaintiff sued the PAC and the PAC then found OMA violations, plaintiff sought litigation costs under 5 ILCS 120/3(d). The court affirmed denial of costs, holding section 3 authorizes actions against public bodies, not against the PAC for delay under section 3.5, so no right of action ag

https://illinoisfoia.org/opinions/letter-91103/ 2026-06-12T00:00:00Z

Under OMA, a public body must describe the general subject matter of a final action on its agenda (section 2.02(c)). The park district board voted in open session in October to select a specific candidate for a vacant commissioner seat, but its agenda listed only 'Personnel' and 'Approve Items Discussed in Executive Session,' which gave no notice of an appointment, so the PAC found a notice violation; the December agenda was adequate and ratified the action, so no further remedy was needed. The

https://illinoisfoia.org/opinions/letter-94362/ 2026-06-11T00:00:00Z

Under FOIA, a public body may withhold records if another statute specifically prohibits disclosure. Here, the Genetic Information Privacy Act (GIPA) sections 15(a) and 15(b) bar the Sheriff's Office from disclosing genetic testing reports derived from a biological sample. Because the requested Parabon Nanolabs phenotype report is exactly that type of record, the denial was proper and no further action was warranted.

https://illinoisfoia.org/opinions/letter-93241/ 2026-06-10T00:00:00Z

Under OMA section 2.06(g), a public body may not restrict public comment based on content or viewpoint, but brief interruptions that do not meaningfully interfere with a speaker's ability to complete their comment are permissible. Here, the Mayor's two brief comments caused only a momentary pause, after which the speaker continued without interruption until being removed. Because the interruptions did not prevent the speaker from addressing the Board, no violation occurred.

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/2026-pac-92914/ 2026-05-15T00:00:00Z

The requester alleged that a village board voted to terminate a police officer's employment under a meeting agenda item that listed only "Personnel issues" without identifying the employee's category or type of personnel action. The Public Access Counselor held that this generic listing failed to satisfy the Open Meetings Act's requirement that an agenda set forth the general subject matter of anticipated final action with sufficient detail to inform the public. The board was directed to re-vote

https://illinoisfoia.org/opinions/2026-pac-92498/ 2026-05-13T00:00:00Z

The requester alleged that a city council improperly discussed the future of its existing City Hall building in closed sessions that were justified as covering the potential purchase of other real property. The Public Access Counselor held that the council's discussions of the current building's condition and disposition were a separate topic not authorized by the real-property-acquisition exception under which the meetings were closed. The council was directed to disclose the portions of the cl

https://illinoisfoia.org/opinions/letter-87466/ 2026-05-08T00:00:00Z

Section 2.06(g) gives the public a right to address a public body under that body's established and recorded rules. The university board argued this lets it adopt any rule it likes and refused a speaker who asked two days before a meeting because it required written requests three business days ahead. The PAC rejected that reading, reasoning that the right to address officials would be meaningless if a body could impose any limit on comment simply by recording a rule, found that the advance-requ

https://illinoisfoia.org/opinions/letter-83705/ 2026-04-23T00:00:00Z

Under FOIA, a public body must prove by clear and convincing evidence that an exemption applies. The Sheriff's Office claimed that ALPR camera location records were exempt under section 7(1)(d-7) (law enforcement security measures) and 7(1)(v) (vulnerability assessments). However, the PAC found that the Sheriff's Office failed to provide specific facts showing that disclosing the locations would actually increase the risk of attacks or compromise security measures. Because the Sheriff's Office d

https://illinoisfoia.org/opinions/2026-pac-91898/ 2026-04-17T00:00:00Z

The requester, a village trustee, alleged that a village board's mayor cited a "personnel" closed-session exception but then discussed businesses' overdue tax-increment-financing loans instead. The Public Access Counselor held that the board violated the Open Meetings Act's procedure for entering closed session by failing to publicly cite and record the actual exception relied upon, and that the loan discussion was not shown to involve probable or imminent litigation as later claimed. The board

https://illinoisfoia.org/opinions/letter-91277/ 2026-04-02T00:00:00Z

Under FOIA, a public body may deny a repeated request under section 3(g) if it is unduly burdensome. A request is considered repeated if it seeks the same records as a prior request from the same requester. Here, the requester's second request sought insurance records that were already provided in response to the first request, even though the requester claimed it was a clarification. The decisive fact was that the second request covered the same subject matter and time period as the first, and

https://illinoisfoia.org/cases/2026%20IL%20App%20(1st)%20252112-U/ 2026-03-27T00:00:00Z

This is a criminal case where the court addressed the improper application of civil discovery rules to restrict public access to records. The court reversed the trial court's protective order, noting that the decision does not preclude future nondisclosure claims under FOIA by the record custodians.

https://illinoisfoia.org/opinions/letter-91361/ 2026-03-13T00:00:00Z

Under OMA, public bodies must hold meetings with a quorum physically present unless a specific statutory exception applies. The only remote-meeting exceptions are for certain disaster declarations by the Governor or the Director of the Illinois Department of Public Health, not for a local executive order by a municipal head. Because the Board relied solely on the Village President's civil emergency declaration—which OMA does not recognize as a valid basis for remote meetings—the meetings violate

https://illinoisfoia.org/cases/2026%20IL%20App%20(1st)%20241435-U/ 2026-03-02T00:00:00Z

The court affirmed the trial court's finding that the City's search for records was reasonable and adequate. However, it reversed the grant of summary judgment regarding statutory civil penalties, remanding for an evidentiary hearing to determine if the City's delayed production of records was willful or in bad faith.

https://illinoisfoia.org/cases/2026%20IL%20App%20(5th)%20241062-U/ 2026-02-24T00:00:00Z

The court affirmed the dismissal of the plaintiff's complaint because he failed to comply with statutory requirements for submitting FOIA requests. Consequently, the defendant never received the requests, and its duty to respond was never triggered.

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/cases/2026%20IL%20App%20(5th)%20241354/ 2026-02-10T00:00:00Z

The appellate court reversed the circuit court's dismissal of a FOIA complaint, holding that the public bodies failed to demonstrate compliance with the statutory requirements of 5 ILCS 140/3(g) regarding the opportunity to narrow burdensome requests. The case was remanded for further proceedings to ensure proper adherence to FOIA's procedural prerequisites.

https://illinoisfoia.org/opinions/letter-91731/ 2026-02-03T00:00:00Z

Under the Law Enforcement Officer-Worn Body Camera Act (50 ILCS 706/10-20(b)), a requester may obtain body camera footage only if they are the subject of the encounter captured on the recording, or if the footage is flagged for a specific reason (e.g., arrest, use of force, or a complaint). The decisive fact here was that the requester was not present during the encounter and therefore was not a subject of the encounter, even though he was the petitioner in the restraining order matter. Because

https://illinoisfoia.org/cases/2026%20IL%20App%20(1st)%20232227/ 2026-01-27T00:00:00Z

The court held that a FOIA request is considered 'received' when it arrives at the public body's server, regardless of whether a third-party security filter holds the email in a queue. Because Metra failed to respond within the statutory five-business-day period from the date of receipt, the court ruled that Metra forfeited its arguments against compliance and the plaintiff was entitled to attorney fees as the prevailing party.

https://illinoisfoia.org/opinions/2025-pac-90575/ 2026-01-21T00:00:00Z

The requester, a resident, alleged that a village mayor improperly interrupted her public comment, cut off the microphone, and threatened to have her removed after she stated the names of trustees during a board meeting. The Public Access Counselor held that because the board had no established, recorded rule against naming trustees during public comment, the mayor's interference violated the Open Meetings Act's guarantee of an opportunity to address public officials. The board was directed to e

https://illinoisfoia.org/opinions/letter-90484/ 2026-01-13T00:00:00Z

ProPublica requested 911 audio recordings from the Lake County Sheriff's Office, which redacted the decedent's statements, citing privacy concerns for surviving family members. The Illinois Attorney General's Public Access Bureau reviewed the request and concluded that the Sheriff's Office improperly redacted the recording. The Bureau found that the Sheriff's Office failed to show that privacy interests outweighed the public interest in disclosure, distinguishing the case from precedent involvin

https://illinoisfoia.org/opinions/letter-90586/ 2026-01-05T00:00:00Z

A requester asked a school district for a large volume of documents, and the PAC reviewed the district's response. The PAC decided to close the case without taking formal action against the district, but reminded the district that it must clearly explain when it does not have records responsive to specific parts of a request. The PAC also advised the requester to keep future complaints focused strictly on FOIA and Open Meetings Act issues.

https://illinoisfoia.org/opinions/letter-84086/ 2026-01-02T00:00:00Z

A citizen complained that the Chicago Board of Ethics held a private meeting to discuss a specific advisory opinion, which the citizen believed should have been public. The Attorney General's office reviewed the meeting records and agreed that the Board broke the law by keeping that discussion private. The Board has been asked to release the minutes and recording of that specific portion of the meeting.

https://illinoisfoia.org/opinions/2025-pac-89395/ 2025-12-31T00:00:00Z

The requester sought an unredacted copy of a village clerk's termination letter, which the village withheld citing personnel-record and workplace-privacy statutes and FOIA's personal-privacy and disciplinary-adjudication exemptions. The Public Access Counselor held that no cited statute prohibited disclosure of the letter, that it concerned the performance of public duties rather than private affairs, and that the village had not shown any formal adjudication occurred. The village was directed t

https://illinoisfoia.org/opinions/letter-90893/ 2025-12-30T00:00:00Z

A citizen complained to the Attorney General that the Thornton Township Board failed to stop a hostile confrontation that occurred after a public meeting, arguing it discouraged public participation. The PAC reviewed the complaint and concluded that no violation of the Open Meetings Act occurred, though they suggested the Board consider additional security measures if tensions continue. The file is now closed.

https://illinoisfoia.org/opinions/letter-91083/ 2025-12-24T00:00:00Z

A citizen requested bank statements from the Village of Minier and asked for them in electronic format to avoid fees. The Village stated they only keep these records on paper and charged a fee to copy them, which the citizen challenged. The Attorney General's office ruled that the Village is allowed to charge for paper copies because they are not required to scan paper documents into an electronic format for a FOIA request.

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-89570/ 2025-12-15T00:00:00Z

A school board was accused of not being clear enough on its meeting agendas about what specific actions it planned to vote on. The Attorney General's office agreed, finding that vague terms like 'Resignation(s)' or 'Employment' did not give the public enough information. Because the board promised to be more specific in the future, the case was closed without further action.

https://illinoisfoia.org/opinions/letter-87758/ 2025-12-12T00:00:00Z

A citizen complained that the Aurora Civic Center Authority Board's meeting minutes were too vague, failed to record votes on closed session, and that the board hadn't reviewed its closed session minutes as required. The Public Access Bureau found that the board violated the Open Meetings Act because the minutes for three meetings did not adequately summarize discussions. The board acknowledged the other issues and took steps to resolve them, so the determination only addressed the minutes. No o

https://illinoisfoia.org/opinions/2025-pac-88767/ 2025-12-03T00:00:00Z

The requester sought body-worn and dashboard camera footage of an incident involving himself, and a police department demanded pre-payment of a per-minute redaction fee before releasing the video. The Public Access Counselor held that FOIA authorizes a public body to charge only the actual cost of the recording medium for electronic copies, and that the cost of performing redactions is not a chargeable fee under the Act. The department was directed to provide the video footage subject to appropr