Opinions

Honest and Open Government

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PAC Binding Opinions

PAC Binding Opinions - 2024

PUBLIC ACCESS OPINION 24-001 (Request for Review 2023 PAC 78717)
FREEDOM OF INFORMATION ACT: Disclosure of Settlement Agreements

PUBLIC ACCESS OPINION 24-002 (Request for Review 2023 PAC 79369)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 24-003 (Request for Review 2024 PAC 79650)
OPEN MEETINGS ACT: Taking Final Action in Closed Session

PUBLIC ACCESS OPINION 24-004 (Request for Review 2024 PAC 79748)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 24-005 (Request for Review 2024 PAC 79729)
FREEDOM OF INFORMATION ACT: Disclosure of Video Footage

PUBLIC ACCESS OPINION 24-006 (Request for Review 2023 PAC 79453)
FREEDOM OF INFORMATION ACT: Basis for Withholding Police Reports Related to Death of Missing Person

PUBLIC ACCESS OPINION 24-007 (Request for Review 2024 PAC 80807)
OPEN MEETINGS ACT: Attendance by Means Other Than Physical Presence Because of Employment Purposes; Taking Final Action on Matter Not on Meeting Agenda

PUBLIC ACCESS OPINION 24-008 (Request for Review 2024 PAC 81170)
FREEDOM OF INFORMATION ACT: Meaning of "Security Measures" in Section 7(1)(v) of FOIA

PUBLIC ACCESS OPINION 24-009 (Request for Review 2024 PAC 81336)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 24-010 (Requests for Review 2024 PAC 81711, 81713, 81822, 82032, 82045)
OPEN MEETINGS ACT: Duty to Make Meetings Convenient and Open to the Public

Public Access Opinion 24-011 (Request for Review 2024 PAC 82164)
FREEDOM OF INFORMATION ACT: Public Body Must Prove How Disclosure of All Records Withheld Under Section 7(1)(d)(i) of FOIA Would Interfere With a Pending Law Enforcement Investigation

PUBLIC ACCESS OPINION 24-012 (Requests for Review 2024 PAC 81978)
FREEDOM OF INFORMATION ACT: Home or Personal Telephone Numbers of Witnesses to Traffic Crashes

PUBLIC ACCESS OPINION 24-013 (Request for Review 2024 PAC 82412)
OPEN MEETINGS ACT: Notice of a Change in Regular Meeting Dates

PUBLIC ACCESS OPINION 24-014 (Request for Review 2024 PAC 83650)
FREEDOM OF INFORMATION ACT: Duty to Conduct Reasonable Search for Responsive Records; Duty to Disclose Public Records

PUBLIC ACCESS OPINION 24-015 (Request for Review 2024 PAC 83788)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PAC Binding Opinions - 2023

PUBLIC ACCESS OPINION 23-001 (Request for Review - 2022 PAC 73904)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 23-002 (Request for Review - 2022 PAC 73915)
FREEDOM OF INFORMATION ACT: Employee Survey Results Used in Connection with Preparing a Performance Evaluation Are Exempt from Disclosure Pursuant to Section 7(1)(f)

PUBLIC ACCESS OPINION 23-003 (Request for Review - 2023 PAC 74768)
OPEN MEETINGS ACT: Improper Private Meeting

PUBLIC ACCESS OPINION 23-004 (Request for Review - 2023 PAC 74927)
OPEN MEETINGS ACT: Requirement to Provide General Subject Matter of Personnel Transactions on Meeting Agenda

PUBLIC ACCESS OPINION 23-005 (Request for Review - 2023 PAC 75460)
OPEN MEETINGS ACT: Improper Closed Session Discussion of Various Topics Under the Exception for Setting the Price For Sale or Lease of Property

PUBLIC ACCESS OPINION 23-006 (Request for Review - 2023 PAC 75510)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 23-007 (Request for Review - 2023 PAC 75559)
FREEDOM OF INFORMATION ACT: Improper Denial of a Request as Unduly Burdensome

PUBLIC ACCESS OPINION 23-008 (Request for Review - 2023 PAC 76033)
FREEDOM OF INFORMATION ACT: Improper Treatment of FOIA Request as Request for Commercial Purpose and Improper Assessment of Fee

PUBLIC ACCESS OPINION 23-009 (Request for Review - 2023 PAC 76309)
FREEDOM OF INFORMATION ACT: Police Reports Concerning Public Employee Arrested and Charged with Crimes Against a Minor are Not Exempt from Disclosure in their Entireties under the Personal Privacy Exemption

PUBLIC ACCESS OPINION 23-010 (Request for Review - 2023 PAC 76670)
FREEDOM OF INFORMATION ACT: Police Reports Concerning Both a Juvenile Offender and Adult Offender are Exempt from Disclosure under the Juvenile Court Act of 1987

PUBLIC ACCESS OPINION 23-011 (Request for Review - 2023 PAC 76017)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 23-012 (Request for Review - 2023 PAC 76732)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 23-013 (Request for Review - 2023 PAC 76732)
OPEN MEETINGS ACT: Restriction of Public Comment is Limited to Established and Recorded Rules Governing Public Comment

PUBLIC ACCESS OPINION 23-014 (Request for Review - 2023 PAC 78444)
OPEN MEETINGS ACT: Taking Final Action in Closed Session

PUBLIC ACCESS OPINION 23-015 (Request for Review - 2023 PAC 77982)
FREEDOM OF INFORMATION ACT: Non-disclosure Agreement Concerning Planned Commercial Development Project That Has Been Publicly Announced is Not Exempt under Section 7(1)(g) of FOIA

PUBLIC ACCESS OPINION 23-016 (Request for Review - 2023 PAC 78356)
OPEN MEETINGS ACT: Improper Closed Session Discussion of Removing Book from Curriculum

PUBLIC ACCESS OPINION 23-017 (Request for Review - 2023 PAC 78419)
FREEDOM OF INFORMATION ACT – Duty to Respond to FOIA Requests

PAC Binding Opinions - 2022

PUBLIC ACCESS OPINION 22-001 (Request for Review - 2021 PAC C-0536)
FREEDOM OF INFORMATION ACT: Communications Attorney Provides to Client Containing Legal Advice Protected by Attorney-Client Privilege

PUBLIC ACCESS OPINION 22-002 (Request for Review - 2021 PAC 68752)
FREEDOM OF INFORMATION ACT: Section 7(1)(d)(vii) of FOIA Requires Public Body to Prove Investigation is Ongoing And That Disclosure of the Information Would Obstruct the Investigation

PUBLIC ACCESS OPINION 22-003 (Request for Review - 2021 PAC 69031)
OPEN MEETINGS ACT: Improper Remote Meeting During a Public Health Emergency

PUBLIC ACCESS OPINION 22-004 (Request for Review - 2022 PAC 69424)
FREEDOM OF INFORMATION ACT: E-mail from Police Chief to Staff Concerning Policies, Procedures, and Employee Conduct is a Public Record That is Not Exempt from Disclosure under Sections 7(1)(c) or 7(1)(f) of FOIA

PUBLIC ACCESS OPINION 22-005 (Request for Review - 2021 PAC 69011)
FREEDOM OF INFORMATION ACT: Disclosure of Complaints Alleging Public Employee Misconduct

PUBLIC ACCESS OPINION 22-006 (Request for Review - 2022 PAC 69940)
OPEN MEETINGS ACT: Taking Final Action on Matter Not on Meeting Agenda

PUBLIC ACCESS OPINION 22-007 (Request for Review - 2022 PAC 70322)
OPEN MEETINGS ACT: Improper Remote Meetings During a Public Health Emergency

PUBLIC ACCESS OPINION 22-008 (Request for Review - 2022 PAC 71237)
OPEN MEETINGS ACT: Taking Final Action on Matter Not Sufficiently Identified on Meeting Agenda

PUBLIC ACCESS OPINION 22-009 (Request for Review - 2022 PAC 70948)
FREEDOM OF INFORMATION ACT: Section 7.5(zz) of FOIA Exempts from Disclosure Information Identifying City Employees in Bargaining Unit Positions Represented By a Particular Union

PUBLIC ACCESS OPINION 22-010 (Request for Review - 2022 PAC 71177)
OPEN MEETINGS ACT: Failure to Cite an Applicable Exception Before Closing a Meeting to the Public; Improper Discussion of Bids for a Student Transportation Contract in Closed Session

PUBLIC ACCESS OPINION 22-011 (Request for Review - 2022 PAC 71261)
FREEDOM OF INFORMATION ACT: Applications of Individuals Not Appointed to Village Board of Trustees are Public Records and Are Not Exempt from Disclosure Under Sections 7(1)(c) or 7(1)(f) of FOIA

PUBLIC ACCESS OPINION 22-012 (Request for Review - 2022 PAC 72503)
OPEN MEETINGS ACT: Improper Closed Session Discussion of New School Under the Exception for Purchasing or Leasing Real Property

PUBLIC ACCESS OPINION 22-013 (Request for Review - 2022 PAC 73136)
FREEDOM OF INFORMATION ACT: Evidentiary and Discovery Rules Do Not Exempt From Disclosure Private Attorney's Letter on Behalf of Clients

PUBLIC ACCESS OPINION 22-014 (Request for Review - 2022 PAC 74070)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PAC Binding Opinions - 2021

PUBLIC ACCESS OPINION 21-001 (Request for Review - 2020 PAC 65160) (January 26, 2021)
FREEDOM OF INFORMATION ACT: Duty to Confer Before Denying Request as Unduly Burdensome

PUBLIC ACCESS OPINION 21-002 (Request for Review - 2020 PAC 65525) (February 17, 2021)
FREEDOM OF INFORMATION ACT: Police Records Concerning Sexual Offenses Against Minors Allegedly Perpetrated by Adults

PUBLIC ACCESS OPINION 21-003 (Request for Review - 2020 PAC 65927) (March 4, 2021)
OPEN MEETINGS ACT: Improper Discussion of Matters under the Exception for Pending, Probable, or Imminent Litigation

PUBLIC ACCESS OPINION 21-004 (Request for Review - 2021 PAC 66968) (May 24, 2021)
FREEDOM OF INFORMATION ACT: Correspondence Shared With a Third Party Who Represents Independent Interests Is Not Part of a Public Body's Deliberative Process

PUBLIC ACCESS OPINION 21-005 (Request for Review - 2021 PAC 67100)(June 2, 2021)
FREEDOM OF INFORMATION ACT: Duty to Disclose Employee Attendance Records

PUBLIC ACCESS OPINION 21-006 (Request for Review - 2021-PAC-S-0079)(July 7, 2021)
OPEN MEETINGS ACT: Duty to Make Verbatim Recordings of Closed Sessions of Committee Meetings

PUBLIC ACCESS OPINION 21-007 (Request for Review - 2021-PAC-S-0121)(July 27, 2021)
FREEDOM OF INFORMATION ACT: Names Not Exempt as Personal Information Absent Private or Confidential Circumstances that Outweigh Any Legitimate Public Interest in Disclosure

PUBLIC ACCESS OPINION 21-008 (Request for Review - 2021-PAC-C-0090)(August 31, 2021)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 21-009 PDF (Request for Review - 2021-PAC-C-0069)(September 21, 2021)
OPEN MEETINGS ACT: Duty to Provide Opportunity for Public Comment in Open Session

PUBLIC ACCESS OPINION 21-010 (Request for Review - 2021-PAC-C-0067)(October 12, 2021)
FREEDOM OF INFORMATION ACT: Names of City Employees Who Engaged in Misconduct Are Subject to Disclosure

PUBLIC ACCESS OPINION 21-011 (Request for Review - 2021-PAC-C-0385) (December 14, 2021)
OPEN MEETINGS ACT: Proper Remote Meeting During a Public Health Emergency

PUBLIC ACCESS OPINION 21-012 (Request for Review - 2021-PAC-S-0806) (December 16, 2021)
FREEDOM OF INFORMATION ACT: Disclosure of 911 Response Times

PAC Binding Opinions - 2020

PUBLIC ACCESS OPINION 20-001 (Request for Review - 2019 PAC 60592)
OPEN MEETINGS ACT: Duty to Approve Meeting Minutes Within Time Period Specified by OMA

PUBLIC ACCESS OPINION 20-002 (Request for Review - 2019 PAC 60399)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 20-003 (Request for Review - 2020 PAC 61510)
FREEDOM OF INFORMATION ACT: Disclosure of Applications for Adult Use Cultivation Center Licenses

PUBLIC ACCESS OPINION 20-004 (Request for Review - 2020 PAC 62037)
OPEN MEETINGS ACT: Discussion of the Process for Evaluating an Employee in Closed Session

PUBLIC ACCESS OPINION 20-005 (Request for Review - 2020 PAC 62350)
FREEDOM OF INFORMATION ACT: Disclosure of Police Dashboard Camera Video, Dispatch Audio, and Written Critique

PUBLIC ACCESS OPINION 20-006 (Request for Review - 2020 PAC 62579)
FREEDOM OF INFORMATION ACT: Records Directly Related to Providing Medical Care to Inmates in Possession of Third Party Contracted to Provide Medical Care to Inmates are Public Records of Illinois Department of Corrections

PUBLIC ACCESS OPINION 20-007 (Request for Review - 2020 PAC 64741)
OPEN MEETINGS ACT: Requirement for the Public to Contemporaneously Hear All Discussion, Testimony, and Roll Call Votes in a Meeting Held Remotely Pursuant to a Public Health Emergency

PUBLIC ACCESS OPINION 20-008 PDF document (Request for Review 2020 PAC 64668)
REEDOM OF INFORMATION ACT: Juvenile Court Act of 1987 Does Not Prohibit Disclosure of Police Records Where a Minor is a Victim

PUBLIC ACCESS OPINION 20-009 (Request for Review - 2020 PAC 65678)
FREEDOM OF INFORMATION ACT: Disclosure of Arrest Reports and Corresponding Police Records

PUBLIC ACCESS OPINION 20-010 (Request for Review - 2020 PAC 65331)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PAC Binding Opinions - 2019

PUBLIC ACCESS OPINION 19-001 (Request for Review - 2018 PAC 55193)
FREEDOM OF INFORMATION ACT: Disclosure of Officer-Worn Body Camera Footage under the Law Enforcement Officer-Worn Body Camera Act

PUBLIC ACCESS OPINION 19-002 (Request for Review - 2018 PAC 55462)
OPEN MEETINGS ACT: "Established" and Recorded Rules for Public Comment

PUBLIC ACCESS OPINION 19-003 (Request for Review - 2018 PAC 55659)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 19-004 (Request for Review - 2019 PAC 56876)
OPEN MEETINGS ACT: Public Recital of the Nature of the Matter Under Consideration Prior to Taking Final Action

PUBLIC ACCESS OPINION 19-005 (Request for Review - 2019 PAC 56867)
FREEDOM OF INFORMATION ACT: Disclosure of Police Department's Extradition Calendar

PUBLIC ACCESS OPINION 19-006 (Request for Review - 2019 PAC 58242)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 19-007 (Request for Review - 2019 PAC 58468)
FREEDOM OF INFORMATION ACT: Reports of Manganese Throughputs Submitted to a City Public Health Department Are Not Exempt From Disclosure under Section 7(1)(g) of FOIA

PUBLIC ACCESS OPINION 19-008 (Request for Review - 2019 PAC 58547)
FREEDOM OF INFORMATION ACT: Basis for Withholding Police Report Narratives

PUBLIC ACCESS OPINION 19-009 (Request for Review - 2019 PAC 59187)
OPEN MEETINGS ACT: Right to Address Public Officials at a Public Meeting

PUBLIC ACCESS OPINION 19-010 (Request for Review - 2019 PAC 58962)
FREEDOM OF INFORMATION ACT: Disclosure of Body Camera Footage of an Arrestee's Death

PUBLIC ACCESS OPINION 19-011 (Request for Review - 2019 PAC 59091)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 19-012 (Request for Review - 2019 PAC 59426)
OPEN MEETINGS ACT: Taking Final Action on Matter Not Sufficiently Identified on Meeting Agenda

PUBLIC ACCESS OPINION 19-013 (Request for Review - 2019 PAC 59779)
FREEDOM OF INFORMATION ACT: Obligation to Preserve Records After Receiving a FOIA Request

PAC Binding Opinions - 2018

PUBLIC ACCESS OPINION 18-001 (Request for Review - 2017 PAC 49999)

FREEDOM OF INFORMATION ACT: Disclosure of Information in Village President's Resignation Letter

PUBLIC ACCESS OPINION 18-002 (Request for Review - 2017 PAC 50286)

FREEDOM OF INFORMATION ACT: Disclosure of Names of Municipal Water Account Holders

PUBLIC ACCESS OPINION 18-003 (Request for Review - 2017 PAC 50370)

FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 18-004 (Request for Review - 2017 PAC 50559)

FREEDOM OF INFORMATION ACT: Third Party Cost Records Submitted to a City Related to a City-Funded Redevelopment Project Are Not Exempt From Disclosure under Section 7(1)(g) of FOIA

PUBLIC ACCESS OPINION 18-005 (Request for Review - 2017 PAC 50592)

FREEDOM OF INFORMATION ACT: Disclosure of Public Employees' Compensation

PUBLIC ACCESS OPINION 18-006 (Requests for Review - 2018 PAC 52207, 52208, and 52209

FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 18-007 (Request for Review - 2018 PAC 52206)

FREEDOM OF INFORMATION ACT: Public Body's Burden when Denying a Request as an Unduly Burdensome Repeated Request

PUBLIC ACCESS OPINION 18-008 (Request for Review - 2018 PAC 52443)

FREEDOM OF INFORMATION ACT: Improper Denial of a Request for Records as an Unduly Burdensome Repeated Request; Financial Terms Related to a Public Body's Use of Public Funds Are Not Exempt under Section 7(1)(g) of FOIA

PUBLIC ACCESS OPINION 18-009 (Request for Review - 2018 PAC 52464)

FREEDOM OF INFORMATION ACT: Disclosure of Property Index Numbers

PUBLIC ACCESS OPINION 18-010 (Request for Review - 2018 PAC 53172)

FREEDOM OF INFORMATION ACT: Disclosure of General Allegations Against Public Body in a Settlement Agreement

PUBLIC ACCESS OPINION 18-011 (Request for Review - 2018 PAC 53375)

FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 18-012 (Request for Review - 2018 PAC 53879)

OPEN MEETINGS ACT: Improper Discussion of Budget and Layoffs in Closed Session

PUBLIC ACCESS OPINION 18-013 PDF document (Request for Review 2018 PAC 54430)

FREEDOM OF INFORMATION ACT: Improper Denial of a Request for Records as Unduly Burdensome

PUBLIC ACCESS OPINION 18-014 (Request for Review - 2018 PAC 53997)

FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 18-015 (Request for Review - 2018 PAC 54229)

OPEN MEETINGS ACT: Discussion of the Duties and Salaries of Elected Officials in Closed Session

PUBLIC ACCESS OPINION 18-016 (Request for Review - 2018 PAC 54236)

REEDOM OF INFORMATION ACT: Disclosure of Records of Traffic Crashes Involving Minor Passengers

PUBLIC ACCESS OPINION 18-017 (Request for Review - 2018 PAC 55035)

FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 18-018 (Request for Review - 2018 PAC 55153)

FREEDOM OF INFORMATION ACT: Disclosure of Complaints Against Public Employees

PAC Binding Opinions - 2017

PUBLIC ACCESS OPINION 17-001 (Request for Review - 2017 PAC 45894)
FREEDOM OF INFORMATION ACT: Basis for Withholding Police Investigatory Records

PUBLIC ACCESS OPINION 17-002 (Request for Review - 2017 PAC 45923)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 17-003 (Request for Review - 2017 PAC 46400)
FREEDOM OF INFORMATION ACT: Financial Terms of Contracts, Billing Invoices, and Budget Documents Related To a Public Body's Use of Public Funds Are Not Exempt under Section 7(1)(g) of FOIA

PUBLIC ACCESS OPINION 17-004 (Request for Review - 2017 PAC 46720)
OPEN MEETINGS ACT: Discussion of Legal Matters under the Exception for Pending, Probable, or Imminent Litigation

PUBLIC ACCESS OPINION 17-005 (Request for Review - 2017 PAC 46589)
FREEDOM OF INFORMATION ACT: Statistical Data is Not Exempt from Disclosure under Section 7(1)(f) of FOIA

PUBLIC ACCESS OPINION 17-006 (Request for Review - 2017 PAC 46587)
FREEDOM OF INFORMATION ACT: Disclosure of Information Related to State Employees Designated as Essential+-

PUBLIC ACCESS OPINION 17-007 (Request for Review - 2017 PAC 46838)
FREEDOM OF INFORMATION ACT: Duty to Respond to a FOIA Request for Records of a City Appointed Board and Related to City-Owned Property

PUBLIC ACCESS OPINION 17-008 (Request for Review - 2017 PAC 47743)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 17-009 (Request for Review - 2017 PAC 47126)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 17-010 (Request for Review - 2017 PAC 48071)
FREEDOM OF INFORMATION ACT: Disclosure of Contractor's Employees' Names in Certified Payroll Records

PUBLIC ACCESS OPINION 17-011 (Requests for Review - 2017 PAC 47695 & 2017 PAC 47696)
FREEDOM OF INFORMATION ACT: Disclosure of 9-1-1 Call Recordings

PUBLIC ACCESS OPINION 17-012 (Request for Review - 2017 PAC 49564)
FREEDOM OF INFORMATION ACT: Disclosure of Recordings of Public Meetings

PUBLIC ACCESS OPINION 17-013 (Request for Review - 2017 PAC 49332)
OPEN MEETINGS ACT: Discussion of the Conduct of a Public Body Member in Closed Session

PUBLIC ACCESS OPINION 17-014 (Request for Review - 2017 PAC 49554)
FREEDOM OF INFORMATION ACT: Purpose of Request Invalid Basis On Which to Withhold Public Records

PUBLIC ACCESS OPINION 17-015 (Request for Review - 2017 PAC 49833)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PAC Binding Opinions - 2016

PUBLIC ACCESS OPINION 16-001 (Request for Review - 2015 PAC 38674)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 16-002 (Request for Review - 2015 PAC 38303)
FREEDOM OF INFORMATION ACT: Disclosure of Post-mortem Photographs to the Executor of the Decedent's Estate

PUBLIC ACCESS OPINION 16-003 (Request for Review - 2016 PAC 39853)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 16-004 (Request for Review - 2016 PAC 41880)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests; Duty to Provide Timely Notification of Extension for Responding to FOIA Requests

PUBLIC ACCESS OPINION 16-005 (Request for Review - 2016 PAC 41381)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 16-006 (Request for Review - 2016 PAC 41657)
FREEDOM OF INFORMATION ACT: Disclosure of E-Mails from Public Employees' Personal E-Mail Accounts Pertaining to Transaction of Public Business; Duty to Conduct Reasonable Search for Responsive Records

PUBLIC ACCESS OPINION 16-007 (Request for Review - 2016 PAC 42395)
OPEN MEETINGS ACT: Discussion of Legal Matters Under the Exception for Pending, Probable, or Imminent Litigation

PUBLIC ACCESS OPINION 16-008 (Request for Review - 2016 PAC 43069)
FREEDOM OF INFORMATION ACT: Improper Denial of a Request for Records as Unduly Burdensome

PUBLIC ACCESS OPINION 16-009 (Requests for Review - 2016 PAC 43168, 43184, 43186, 43193 and 43370)
FREEDOM OF INFORMATION ACT: Disclosure of Certain Information in a Criminal Complaint Filed by a Public Figure

PUBLIC ACCESS OPINION 16-010 (Request for Review - 2016 PAC 43297)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 16-011 (Request for Review - 2016 PAC 44066)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 16-012 (Request for Review - 2016 PAC 44115)
FREEDOM OF INFORMATION ACT: Disclosure of Public Employees' Compensation

PUBLIC ACCESS OPINION 16-013 (Request for Review - 2016 PAC 44249)
OPEN MEETINGS ACT: Improper Discussion of Salary Increases for City Employees in a Closed Meeting

PUBLIC ACCESS OPINION 16-014 (Request for Review - 2016 PAC 44337)
OPEN MEETINGS ACT: Right to Record an Open Meeting

PUBLIC ACCESS OPINION 16-015 (Request for Review - 2016 PAC 45117)
OPEN MEETINGS ACT: Taking Final Action on Matter Not on Meeting Agenda

PAC Binding Opinions - 2015

PUBLIC ACCESS OPINION 15-001 (Request for Review - 2014 PAC 31609)
FREEDOM OF INFORMATION ACT: Production of Records to the Public Access Counselor; Disclosure of Records of the State Board of Professional Engineers

PUBLIC ACCESS OPINION 15-002 (Request for Review - 2014 PAC 31746)
FREEDOM OF INFORMATION ACT: Home Rule Ordinance Does Not Supersede FOIA; Negotiated Terms of Contracts with Public Bodies Do Not Constitute Trade Secrets; Correspondence With Third Parties Is Not Part of A Public Body's Deliberative Process

PUBLIC ACCESS OPINION 15-003 (Request for Review - 2015 PAC 33652)
OPEN MEETINGS ACT: Improper Discussion of Financial Matters and Disposal of Property in a Closed Meeting

PUBLIC ACCESS OPINION 15-004 (Request for Review - 2015 PAC 33991)
FREEDOM OF INFORMATION ACT: Disclosure of Settlement Agreements

PUBLIC ACCESS OPINION 15-005 (Request for Review - 2015 PAC 35119)
OPEN MEETINGS ACT: Failure to Cite Closed Session Exception; Improper Discussion of Proposed Police Services Contract in Closed Session; Taking Final Action on Matter Not on Meeting Agenda

PUBLIC ACCESS OPINION 15-006 (Request for Review - 2015 PAC 35427)
FREEDOM OF INFORMATION ACT: Disclosure of Public Employees' Compensation

PUBLIC ACCESS OPINION 15-007 (Request for Review - 2015 PAC 35861)
OPEN MEETINGS ACT: Failure to Cite an Applicable Exception Before Closing a Meeting to the Public; Improper Discussion of a Hiring Freeze in a Closed Meeting

PUBLIC ACCESS OPINION 15-008 (Request for Review - 2015 PAC 35747)
FREEDOM OF INFORMATION ACT: Disclosure of the Governor's Calendar

PUBLIC ACCESS OPINION 15-009 (Request for Review - 2015 PAC 35840)
FREEDOM OF INFORMATION ACT: Disclosure of Surveillance Video Recordings

PUBLIC ACCESS OPINION 15-010 (Request for Review - 2015 PAC 36285)
FREEDOM OF INFORMATION ACT: Disclosure of General Information Concerning Outside Counsel Representing State Agencies

PUBLIC ACCESS OPINION 15-011 (Request for Review - 2015 PAC 36548)
FREEDOM OF INFORMATION ACT: Failure to Timely Respond to FOIA Request Precludes Denial as Unduly Burdensome; Disclosure of Certified Payroll Records

PUBLIC ACCESS OPINION 15-012 (Request for Review - 2015 PAC 37849)
FREEDOM OF INFORMATION ACT: Failure to Respond to FOIA Request; Extension of the Response Period

PUBLIC ACCESS OPINION 15-013 (Request for Review - 2015 PAC 37664)
FREEDOM OF INFORMATION ACT: Failure to Respond to FOIA Requests

PUBLIC ACCESS OPINION 15-014 (Request for Review - 2015 PAC 37249)
FREEDOM OF INFORMATION ACT: Duty to Disclose Public Records in the Possession of a Public Body

PUBLIC ACCESS OPINION 15-015 (Request for Review - 2015 PAC 37506)
FREEDOM OF INFORMATION ACT: Disclosure of Training Materials

PAC Binding Opinions - 2014

PUBLIC ACCESS OPINION 14-001 (Request for Review - 2013 PAC 23488-On Remand)
OPEN MEETINGS ACT: Failure to Sufficiently Inform the Public of the Business Being Conducted before Taking Final Action

PUBLIC ACCESS OPINION 14-002 (Request for Review - 2014 PAC 27500)
FREEDOM OF INFORMATION ACT: Disclosure of Invoices for Legal Services

PUBLIC ACCESS OPINION 14-003 (Request for Review - 2014 PAC 27859)
OPEN MEETINGS ACT: Amending Agenda During 48-Hour Posting Period

PUBLIC ACCESS OPINION 14-004 (Request for Review - 2014 PAC 27773)
FREEDOM OF INFORMATION ACT: Disclosure of Settlement Agreements

PUBLIC ACCESS OPINION 14-005 (Request for Review - 2014 PAC 28485)
FREEDOM OF INFORMATION ACT: Records Documenting Public Funds Paid to Entities Pursuant to Contracts For Performance of A Governmental Function Are Subject to Disclosure

PUBLIC ACCESS OPINION 14-006 (Request for Review - 2014 PAC 28539)
FREEDOM OF INFORMATION ACT: Duty to Disclose Public Records in the Possession of a Public Body

PUBLIC ACCESS OPINION 14-007 (Request for Review - 2014 PAC 29561)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests; Duty to Conduct Reasonable Search for Responsive Records; Duty to Disclose Public Records; A Public Body That Fails to Respond Within the Requisite Period May Not Treat Request as Unduly ...

PUBLIC ACCESS OPINION 14-008 (Request for Review - 2014 PAC 29297)
FREEDOM OF INFORMATION ACT: Disclosure of Photographs of a Former Auxiliary Deputy Sheriff

PUBLIC ACCESS OPINION 14-009 (Request for Review - 2014 PAC 29739)
OPEN MEETINGS ACT: Information Required of Speakers Wishing to Provide Public Comment

PUBLIC ACCESS OPINION 14-010 (Request for Review - 2014 PAC 29590)
FREEDOM OF INFORMATION ACT: Duty to Conduct a Reasonable Search for Responsive Records; Repeat Requests Under Section 3(g).

PUBLIC ACCESS OPINION 14-011 (Request for Review - 2014 PAC 30677; 30678; 30679; 30680)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 14-012 (Request for Review - 2014 PAC 30194)
OPEN MEETINGS ACT: Rules for Public Comment

PUBLIC ACCESS OPINION 14-013 (Request for Review - 2014 PAC 30269)
FREEDOM OF INFORMATION ACT: Photocopies of Records Deemed Exempt from Disclosure under Section 7(1)(e-5)

PUBLIC ACCESS OPINION 14-014 (Request for Review - 2014 PAC 30994)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 14-015 (Request for Review - 2014 PAC 30785)
FREEDOM OF INFORMATION ACT: Disclosure of Resume and Job Application of Public Employee

PUBLIC ACCESS OPINION 14-016 (Request for Review - 2014 PAC 30882)
FREEDOM OF INFORMATION ACT: Disclosure of Terms of Lease Agreements for the Rental of Public Property

PAC Binding Opinions - 2013

PUBLIC ACCESS OPINION 13-001 (Request for Review - 2012 PAC 22708)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 13-002 (Request for Review - 2013 PAC 22987)
OPEN MEETINGS ACT: Taking Final Action on Matters Not Included in Agenda

PUBLIC ACCESS OPINION 13-003 (Request for Review - 2013 PAC 23177)
OPEN MEETINGS ACT: Taking Final Action at Closed Session Prohibited

PUBLIC ACCESS OPINION 13-004 (Request for Review - 2013 PAC 23366)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 13-005 (Request for Review - 2013 PAC 22996)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 13-006 (Requests for Review - 2013 PAC 23358 and 2013 PAC 23376)
OPEN MEETINGS ACT: Secret Ballots Prohibited

PUBLIC ACCESS OPINION 13-007 (Request for Review - 2013 PAC 23488)
OPEN MEETINGS ACT: Taking Final Action at Closed Session Prohibited; Duty to Record Closed Meetings; Summary of Discussion Required in Minutes

PUBLIC ACCESS OPINION 13-008 (Request for Review - 2013 PAC 23545)
OPEN MEETINGS ACT: Requirement to Record and Enter Into Closed Meeting Minutes Basis for Finding that Litigation is Probable or Imminent

PUBLIC ACCESS OPINION 13-009 (Request for Review - 2013 PAC 23495)
FREEDOM OF INFORMATION ACT: Duty to Respond to FOIA Requests

PUBLIC ACCESS OPINION 13-010 (Request for Review - 2013 PAC 23604)
OPEN MEETINGS ACT: Requirement to Publicly Recite Nature of Matter Being Considered and Other Information to Adequately Inform the Public of the Business Being Conducted Before Taking Final Action

PUBLIC ACCESS OPINION 13-011 (Request for Review - 2013 PAC 23559)
FREEDOM OF INFORMATION ACT: Records Relating to a Public Body's Internal Investigation into an Employee's Conduct

PUBLIC ACCESS OPINION 13-012 PDF document (Request for Review 2013 PAC 23857)
FREEDOM OF INFORMATION ACT: Records in the Possession of the Governing Body of a Charter School that Pertain to Public Business Are Public Records

PUBLIC ACCESS OPINION 13-013 (Request for Review - 2013 PAC 24760)
FREEDOM OF INFORMATION ACT: Duty to Furnish Non-Exempt Records and to Issue a Written Denial For Any Records Not Provided

PUBLIC ACCESS OPINION 13-014 (Request for Review - 2013 PAC 24845)
OPEN MEETINGS ACT: A Public Body's Special Meeting Held Approximately 26 Miles from its Ordinary Meeting Location is Not "Convenient and Open" to the Public

PUBLIC ACCESS OPINION 13-015 (Request for Review - 2013 PAC 24905)
FREEDOM OF INFORMATION ACT: Statistical Data is Not Exempt from Disclosure under Section 7(1)(f) of FOIA

PUBLIC ACCESS OPINION 13-016 (Request for Review - 2013 PAC 25078)
OPEN MEETINGS ACT: Duty to Inform the Public of the Nature of the Business under Consideration Prior to Taking Final Action

PUBLIC ACCESS OPINION 13-017 (Request for Review - 2013 PAC 25483)
FREEDOM OF INFORMATION ACT: Duty to Provide "Clear and Convincing "Evidence to Support Assertion of Exemptions; Possibility of Obtaining Public Records through Discovery Does Not Preclude FOIA Requests

PUBLIC ACCESS OPINION 13-018 (Request for Review - 2013 PAC 25736)
FREEDOM OF INFORMATION ACT: Public Records in the Possession of a Contractor Performing a Governmental Function for a Public Body Are Public Records of the Public Body; A Public Body May Not Charge a Requester Fees for the Contractor to Locate…

PAC Binding Opinions - 2012

PUBLIC ACCESS OPINION 12-001 (Request for Review - 2011 PAC 16877)
FREEDOM OF INFORMATION ACT: Classification as a recurrent requester under section 2(g) of FOIA.

PUBLIC ACCESS OPINION 12-002 (Request for Review - 2011 PAC 16946)
FREEDOM OF INFORMATION ACT: Under Section 3(d) of FOIA, Public Bodies Must Respond to a Request for Records Within Five Business Days After Receipt of the Request.

PUBLIC ACCESS REVIEW 12-003 (Request for Review - 2011 PAC 17006)
FREEDOM OF INFORMATION ACT: Names of State University Students and Graduation Information Are Not Exempt from Disclosure under Sections 7(1)(a), 7(1)(b), or 7(1)(c).

PUBLIC ACCESS REVIEW 12-004 (Request for Review - 2011 PAC 17090)
FREEDOM OF INFORMATION ACT: Requests for Records May Properly Be Submitted to a Public Body via Personal Delivery.

PUBLIC ACCESS OPINION 12-005 (Request for Review - 2012 PAC 18205)
FREEDOM OF INFORMATION ACT: Disclosure of Invoices for Legal Services.

PUBLIC ACCESS OPINION 12-006 (Request for Review - 2011 PAC 18379)
FREEDOM OF INFORMATION ACT: Disclosure of Records Pertaining to Arrests and Police Reports.

PUBLIC ACCESS OPINION 12-007 (Request for Review - 2011 PAC 17813)
FREEDOM OF INFORMATION ACT: Production of Records to the Public Access Counselor.

PUBLIC ACCESS OPINION 12-008 (Request for Review - 2012 PAC 18008)
OPEN MEETINGS ACT: Meeting at Private Residence is Not Convenient and Open to the Public

PUBLIC ACCESS OPINION 12-009 (Request for Review - 2012 PAC 18530)
FREEDOM OF INFORMATION ACT: Disclosure of All Non-Exempt Portions of Requested Records

PUBLIC ACCESS OPINION 12-010 (Request for Review - 2012 PAC 18763)
OPEN MEETINGS ACT: Right to Record an Open Meeting.

PUBLIC ACCESS OPINION 12-011 (Request for Review - 2012 PAC 19265)
OPEN MEETINGS ACT: Improper Discussion in Closed Session of Budgetary Matters

PUBLIC ACCESS OPINION 12-012 (Request for Review - 2012 PAC 19602)
FREEDOM OF INFORMATION ACT: Disclosure of Records Relating to the Death of a Minor.

PUBLIC ACCESS OPINION 12-013 (Request for Review - 2012 PAC 20863)
OPEN MEETINGS ACT: Improper Discussion of Proposed Ordinance in Closed Session; Requirement to Recite and Record Basis for Finding that Litigation is Probable or Imminent; Requirement to Record Closed Sessions; Taking Final Action at Closed Session...

PUBLIC ACCESS OPINION 12-014 (Request for Review - 2012 PAC 21157)
FREEDOM OF INFORMATION ACT: Disclosure of Student Test Scores and the Illinois School Student Records Act.

PUBLIC ACCESS OPINION 12-015 (Request for Review - 2012 PAC 21348)
FREEDOM OF INFORMATION ACT: Judicial Inquiry Board is Not a "Public Body" to which FOIA is Applicable.

PAC Binding Opinions - 2011

PUBLIC ACCESS OPINION No. 11-001 (Request for Review - 2010 PAC 10242)

FREEDOM OF INFORMATION ACT: Section 2.15 of FOIA Requires Disclosure of Arrest Reports.

PUBLIC ACCESS OPINION No. 11-002 (Request for Review - 2010 PAC 11568)

FREEDOM OF INFORMATION ACT: Disclosure of Number of Police Officers Assigned to Districts.

PUBLIC ACCESS OPINION No. 11-003 (Request for Review - 2011 PAC 12170)

FREEDOM OF INFORMATION ACT: Unduly Burdensome Requests: A Subsequent FOIA request cannot be deemed "unduly burdensome" unless the public body has either previously disclosed the requested records or properly denied the request.

PUBLIC ACCESS OPINION No. 11-004 (Request for Review - 2011 PAC 12406)

FREEDOM OF INFORMATION ACT : Under Section 2.20 of FOIA, settlement agreements entered into by an intergovernmental risk management association or self-insurance pool on behalf of a public body are subject to disclosure...,

PUBLIC ACCESS OPINION No. 11-005 (Request for Review - 2011 PAC 11946)

FREEDOM OF INFORMATION ACT: Section 7(1)(s) Exemption-Nerve Conduction Velocity Test results obtained with respect to workers' compensation claims are not exempt from disclosure.

PUBLIC ACCESS OPINION No. 11-006 (Request for Review - 2011 PAC 15916)

FREEDOM OF INFORMATION ACT: Public Records -- Electronic records relating to the transaction of public business are "public records" subject to disclosure under section 2(c) of FOIA notwithstanding that...

PUBLIC ACCESS OPINION No. 11-007 (Request for Review - 2011 PAC 17220)

FREEDOM OF INFORMATION ACT: A public body's offer to allow the inspection of public records in response to a request for copies constitutes a violation of section 3(b) of FOIA.

PAC Binding Opinions - 2010

PUBLIC ACCESS OPINION No. 10-001 (Request for Review 2010 PAC 5688)

FREEDOM OF INFORMATION ACT: Duty of Public Body to Furnish Copies

PUBLIC ACCESS OPINION No. 10-002 (Request for Review 2010 PAC 5745)

FREEDOM OF INFORMATION ACT: No Authority for Public Body to Charge for Copies for Its Files

PUBLIC ACCESS OPINION No. 10-003 (Request for Review 2010 PAC 8890, 9217)

Freedom of Information Act: Autopsy Reports

PUBLIC ACCESS OPINION No. 10-004 (Request for Review 2010 PAC 10658)

FREEDOM OF INFORMATION ACT: Settlement Agreements