Township High School District 113 advised on multipart FOIA request obligations

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Dear and Ms. Anderson:

that he had ten business days to amend the request such that it would no longer be voluminous, which he declined to do. Therefore, the District extended its time to respond to the request pursuant to section 3. 6( d) of FOIA. 4 On October 9, 2025, the District respond by providing with a link to the District' s website for the policies and missions statement, citing section 8. 5( a) of FOIA. 5 The District also provided with copies of some records it deemed responsive to the request, but indicated that it redacted and withheld other information and documents pursuant to sections 7( 1)( a), 7( 1)( b), 7( 1)( c), 7( 1)( f), and 7. 5( r) of FOIA. 6 On November 12, 2025, submitted a Request for Review to the Public Access Bureau challenging the District' s response. In his Request for Review, argued, among other things, that "[ n] one of the enumerated requests are responded to individually or specifically. The appended documents shed little if any light as to what the District is responding to what it is ignoring or to which it has no responsive documents." 7 Although FOIA "is not intended to compel public bodies to interpret or advise requesters as to the meaning or significance of the public recordsi8 when a FOIA request contains multiple parts, a public body's response should clearly identify which records correspond to each portion of the request. See Ill. Att'y Gen. PAC Req. Rev. Ltr. 30548, issued July 10, 2015, at 3; see also Rockford Police Benevolent and Protective Assn, Unit No. 6 v. Morrissey, 398 Ill. App. 3d 145, 150 ( 2010) (" To meet its burden * * *, the public body must provide a detailed justification for its claim of exemption, addressing the requested records specifically and in a manner allowing for adequate adversarial testing."). Likewise, if a public body does not maintain any records that respond to portions of a request, it should explicitly tell the requester in its response. See Ill. Att'y Gen. PAC Req. Rev. Ltr. 57553, issued April 22, 2019.

exemptions. Nonetheless, request is unduly burdensome on its face.

Section 3( g) of FOIA9 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.

Illinois courts analyzing section 3( g) of FOIA have determined that a categorical FOIA request seeking a broad range of records must be specifically targeted to advance a significant public interest to outweigh the burden of compliance on a public body. See, for example, Sargent Shriver National Center on Poverty Law, Inc. v. Board of Education of City of Chicago, 2018 IL App ( 1st) 171846, ¶¶ 39- 41 ( determining that although the topic of the school -to -prison pipeline is of significant public interest, the year -long scope of the request for employee misconduct reports in a large school district was indicative of a fishing expedition rather than an appropriately targeted request, such as a request limited to suspected misconduct within a systematic misconduct and a lack of oversight and corrective action. While there is certainly public interest in the disclosure of information regarding the District' s hiring process and alleged misconduct, it is not apparent to this office that the stated public interest warrants the disclosure of all the requested records. See, for example, Ill. Att' y Gen. PAC Req. Rev. Ltr. 47671, issued August 10, 2017, at 4 (" There is no question that the public interest in collective bargaining generally and unionization at Noble is high, but there is no indication that [ the requester' s] request for all e-mails sent or received by the three individuals at issue over that 17- day period containing the broad term ' union' could not be appropriately narrowed to more specifically target records responsive to the purpose of her request."). Although the District did not raise the section 3( g) exemption in its response to the request, it may appropriately offer the opportunity to narrow his request to manageable proportions at this time under these circumstances. See Kelly v. Village ofKenilworth, 2019 IL App ( 1st) 170780, ¶ 49.

Because the FOIA request at issue in this matter is overly broad and because the District' s response lacks sufficient detail concerning the extent to which it possesses responsive records and the nature of the records that were withheld, this office will not take further action at this juncture but instead asks the parties to confer about potentially resolving this matter, at least partially, in a mutually agreeable manner. We suggest that the District confer with to clarify its response and the type of records that were withheld and recommend that significantly narrow the scope of his request to exclude any documents the District has already provided to him and to more specifically target records directly responsive to the purpose of his request. For example, may wish to revise his request for "prior complaints from any source concerning during his tenure as athletic director" 1° to complaints concerning particular topics or subject matters. For each part of the request, the District should issue a response that clearly delineates which specific records correspond to which portion of the request in a manner that would allow for adequate adversarial testing, including explaining whether records responsive to each part of the request were withheld or redacted and a citation to the exemption( s) that the District relied upon for those actions. If the District has no documents responsive to a particular portion ofthe multipart request, it should expressly state that in its This file is closed. If you have FOIA questions, my e- mail address is [email protected].

Very truly yours,

SHANNON BARNABY

Senior Assistant Attorney General Public Access Bureau 90586 f no fi war sd