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FOIADetermination Letter (non-binding)Closed no further actionPersonnel & Student Records

Illinois DOC properly denied federal investigator access to inmate records under 7(1)(a)

The request sought the specific discharge date of an inmate from their Department of Corrections sentence.

Date issued
March 17, 2025
Request number(s)
85755
Public body
Illinois Department of Corrections
Statute(s)
5 ILCS 140/7(1)(a)730 ILCS 5/3-5-1(b)
Exemption(s) discussed
7(1)(a) — Federal/State-law confidentiality — or public defender case files, for documents issued under the other amendment version
Outcome
Closed, no further action

Plain-language summary

A federal investigator asked the Illinois Department of Corrections for an inmate's release date, but the department refused to provide it. The Attorney General's office reviewed the case and agreed with the department, explaining that state law strictly limits who can access these specific records and a signed release from the inmate does not override those legal restrictions. Consequently, the case is closed with no further action required.

Legal question

Whether the Illinois Department of Corrections properly denied a FOIA request for an inmate's master record file information under section 7(1)(a) of FOIA and section 3-5-1(b) of the Unified Code of Corrections.

Holding

The Illinois Department of Corrections did not improperly deny the request for records because the requester is not an authorized party under the Unified Code of Corrections.

Summary

An investigator for the Federal Public Defender requested an inmate's discharge date from the Illinois Department of Corrections (IDOC), which IDOC denied citing confidentiality laws. The PAC determined that IDOC properly denied the request because the relevant statute does not permit disclosure of master record files even with a signed release.

inmate recordsIDOCconfidentialitymaster record file

Reading view (799 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 Ms. Bibulowicz:

This determination letter is issued pursuant to section 9.5(c) of the Freedom of Information Act (FOIA) (5 ILCS 140/9.5(c) (West 2023 Supp.)). For the reasons below, the Public Access Bureau has determined that no further action is warranted in this matter.

On March 5, 2025, you submitted a FOIA request to the Illinois Department of Corrections ( IDOC) in which you stated that you are an Investigator with the Office of the Federal Public Defender and that the Office is representing a named person who provided an authorization permitting the release of records to your office. You requested " records confirming when Mr. was discharged from his DOC sentence in case 03CR0673601 and his exact date of release from confinement." 1 You included a signed release by Mr. with your FOIA request to IDOC for confidential information and records.

On March 13, 2025, IDOC denied your request pursuant to section 7(1)(a) of In your Request for Review, you argued that IDOC erroneously denied your request because the Federal Public Defender' s Office submitted a release of information from its legal client. You included e-mail correspondence you sent to IDOC that questioned why your request was denied and emphasized to IDOC's FOIA officer that you believe your office is authorized to receive the requested information because of Mr. signed release.

IDOC has confirmed that the information you seek is contained in your client's master record file. Although you assert that you are an " authorized person" who is entitled to access your client' s master record file, section 3-5-1(b) of the UCC identifies the parties who may access master record files, and they do not include an investigator nor an attorney. As emphasized above, section 3-5-1(b) permits access to master record files for "authorized personnel" of the respective Department, or pursuant to a court order or subpoena. " Department" is defined in section 3-1-2(e) of the UCC 3 to mean " both the Department of Corrections and the Department of Juvenile Justice of this State, unless the context is specific to either the Department of Corrections or the Department of Juvenile Justice." Additionally, to the extent you believe that the release you provided resolved any confidentiality concerns, section 3-5-1(b) of the UCC does not contain an exception permitting disclosure of master record files upon IDOC's receipt of duly executed releases. Because you are not one of the parties that section 3- 5-1(b) of the UCC permits to access master record files, IDOC did not improperly deny your request under section 7(1)(a) of FOIA. Accordingly, the Public Access Bureau has determined that no further action is warranted in this matter.

Very truly yours, KATIE GOLDSMITH Assistant Attorney General Public Access Bureau 85755 f no fi war sa cc: Via electronic mail Ms. Anne P. Rayhill Freedom of Information Officer Illinois Department of Corrections 1301 Concordia Court P.O. Box 19277 Springfield, Illinois 62794 doc.foiarequest@illinois. gov

Notes from the original PDF (2)
  1. 1Letter from Anna Bibulowicz, Investigator, Office of the Federal Public Defender, to Freedom of Information Act Officer, Illinois Department of Corrections ( March 5, 2025).
  2. 25 ILCS 140/7(1)(a) (West 2023 Supp.), as amended by Public Acts 103-605, effective July 1, 2024; 103-865, effective January 1, 2025. 3730 ILCS 5/3-1-2(e) ( West 2022).