This site is a research reference, not legal advice. See the FAQ disclaimer for details.

← Back to Opinions & Letters

FOIADetermination Letter (non-binding)Closed no further actionFees & Burdensome Requests

Kankakee School District 111 properly denied FOIA request as unduly burdensome under 3(g)

The request sought extensive communications and financial records related to grants, youth programs, and district staffing.

Date issued
October 21, 2024
Request number(s)
82674
Public body
Kankakee School District 111
Statute(s)
5 ILCS 140/3
Outcome
Closed, no further action

Plain-language summary

A requester asked for a large volume of emails and financial documents from a school district. The district claimed the request was too broad and burdensome to fulfill, and the Attorney General's office agreed, noting that the district followed the correct legal steps to ask the requester to narrow the scope of the request.

Legal question

Whether the public body properly denied a FOIA request as unduly burdensome under section 3(g) of FOIA.

Holding

The District properly denied the request as unduly burdensome under section 3(g) of FOIA.

Summary

The requester sought extensive communications and financial records from Kankakee School District 111, which the District denied as unduly burdensome. The PAC determined that the District complied with FOIA's procedural requirements for asserting an undue burden claim and that the burden of compliance outweighed the public interest.

unduly burdensomeFOIA requestschool districtrecords request

Reading view (924 words)

This reading view follows the source PDF's positioned text blocks. Page headers, repeated office furniture, and lower-margin notes are kept out of the narrative; source notes are available below. Reconstruction is automatic and imperfect — the PDF is the authoritative version, and it's linked on this page.

Dear

This determination letter is issued pursuant to section 9.5(c) of the Freedom of Information Act (FOIA). 1 For the reasons stated below, the Public Access Bureau has determined that no further action is warranted as to this matter.

On August 12, 2024, you submitted a FOIA request to Kankakee School District 111 (District) seeking:

All communication between ICJIA and all KSD111 staff and board members communication about the budget managers around the R3 grant from ICJIA All communication that includes: R3, Community partnerships, ICJIA, YEP (Youth Empowerment Program) communication between the current and previous superintendent and any staff member or board member concerning YEP. Communication with the mayor and the states attorney concerning the R3 grant and YEP The amount spent on youth employment during the past ten years In a follow-up e-mail later that evening, you also requested: " W4 of all student workers with identifying information redacted for calendar year 23, 22 and 19, 18 and 17." 3 On August 19, 2024, the District informed you that it found your request to be unduly burdensome under section 3(g) of FOIA 4 and offered you the opportunity to narrow your request. It appears that you did not do so, and instead submitted this Request for Review.

Section 3(g) of FOIA provides, in pertinent part:

Requests calling for all records falling within a category shall be complied with unless compliance with the request would be unduly burdensome for the complying public body and there is no way to narrow the request and the burden on the public body outweighs the public interest in the information. Before invoking this exemption, the public body shall extend to the person making the request an opportunity to confer with it in an attempt to reduce the request to manageable proportions. If any public body responds to a categorical request by stating that compliance would unduly burden its operation and the conditions described above are met, it shall do so in writing, specifying the reasons why it would be unduly burdensome and the extent to which compliance will so burden the operations of the public body. Such a response shall be treated as a denial of the request for information.

This office has previously determined that a request for all communications sent or received by a public official or employee over a period of several weeks or months, which would require a public body to gather and review a large quantity of potentially responsive records, is unduly burdensome under section 3(g) of FOIA in the absence of an identified public interest in disclosure of all of the records that outweighs the burden of compliance with the request. See, Your request is categorical and vast in scope. The District asserted that there are over 680,000 e-mails potentially responsive to seven portions of your request, not counting the records responsive to the other four portions of your request. 5 To collect and review such a large volume of responsive material would impose a significant burden on the District' s operations. Although there is a general public interest in information concerning the District, you have not specified a particular public interest that necessitates the release of all of the requested records. Further, the District met the procedural requirements of section 3(g) by issuing a timely response and offering you the opportunity to confer about narrowing your request to manageable proportions. Under these circumstances, the burden of compliance with your request outweighs the public interest in the records you are seeking. Accordingly, this office concludes that the District did not improperly deny your request as unduly burdensome, and that no further action is warranted as to this matter.

This file is closed. If you have any questions, please contact me at victoria.frazier@ilag. gov. Thank you.

Very truly yours, VICTORIA FRAZIER Assistant Attorney General Public Access Bureau 82674 f no fi war sd

Notes from the original PDF (4)
  1. 15 ILCS 140/9.5(c) (West 2023 Supp.).
  2. 2E-mail from to [Kankakee School District 111] ( August 12, 2024, at 8:25 PM).
  3. 3E-mail from to [Kankakee School District 111] ( August 12, 2024, at 9:13 PM). 45 ILCS 140/3(g) (West 2022).
  4. 5Letter from Rachel Thornton, Freedom of Information Officer, Kankakee School District 111 to August 19, 2024)