City of Champaign v. Madigan

Newspaper reporter made FOIA request for copies of electronic communications sent and received during city council meetings from members of council and mayor. To qualify as a public record a communication must pertain to business or community interests, as FOIA is not concerned with an individual's private affairs. If a communication pertaining to transaction of public business was sent or received during time city council meeting was in session, then communication is a "public record" and is subject to FOIA. Section 11.5 of FOIA does not provide for attorney fees. Section 11(a) of FOIA does not provide for injunctive relief during administrative review process, and thus requester's counterclaim was not appropriate pleading. (APPLETON and HOLDER WHITE, concurring.)