Dumke v. The City of Chicago

Illinois Appellate Court
Civil Court
Citation
Case Number: 
2013 IL App (1st) 121668
Decision Date: 
June 28, 2013
District: 
1st Dist.
Division/County: 
Cook Co., 3d Div.
Justice: 
PIERCE
Holding: 
Reversed.
Plaintiff submitted FOIA request to Chicago Police Department for consultant's final report of assessment of Department operations. Plaintiff filed complaint against City, Mayor, and FOIA officers for their denial of his FOIA request. Mayor publicly cited and identified report in his press conference and press release, and in YouTube video of his press conference, and Mayor thus waived predecisional privilege exemption under Section 7(1)(f) of FOIA. In camera review of report is not appropriate, as Mayor cited entire report as basis for City's decision to reassign police officers. Scope of FOIA disclosure should align with scope of public citation. (NEVILLE and STERBA, concurring.)