Bocock v. McGuire

Illinois Appellate Court
Civil Court
FOIA
Citation
Case Number: 
2017 IL App (3d) 150860
Decision Date: 
Thursday, September 28, 2017
District: 
3d Dist.
Division/County: 
Will Co.
Holding: 
Affirmed.
Justice: 
CARTER

Court properly dismissed with prejudice Plaintiff's complaint against Circuit Court Clerk alleging the manner in which clerk docketed 2 complaints Plaintiff filed pertaining to denial of his requests for information from County sheriff's office that he made pursuant to FOIA.  Plaintiff's complaint did not, and could not, plead sufficient facts to support his request for injunction compelling clerk to conform to statutory requirement of FOIA. Applicable FOIA requests went to County Sheriff's Department, and section 11(j) of FOIA would not apply in a lawsuit against circuit clerk. Exemption for judicial branch from FOIA includes clerks of courts. Plaintiff did not allege that any specific harm resulted from clerk's actions, and did not sufficiently allege that he was deprived of meaningful access to the courts. (HOLDRIDGE and O'BRIEN, concurring.)