Shehadeh v. Madigan

Illinois Appellate Court
Civil Court
Citation
Case Number: 
2013 IL App (4th) 120742
Decision Date: 
October 4, 2013
District: 
4th Dist
Division/County: 
Sangamon Co.
Justice: 
HOLDER WHITE
Holding: 
Affirmed.
FOIA request that Attorney General's office produce any documents that could be used for guidance by any public body in complying with FOIA was patently broad on its face. FOIA does not require that FOIA respondent prove adequacy of its search for records in claiming Section 3(g) exemption from compliance, where breadth of request is evident from face of request. AG's response that employees would have to hand-sort 9,200 documents was sufficient description of extent of burden to respond. (STEIGMANN and HARRIS, concurring.)