Consolidated cases as to competing interests of public disclosure and confidentiality in records generated because of a grand jury investigation. Respect for judicial process requires that a lawful court order must take precedence over the disclosure requirements of FOIA and a public body refusing to disclose documents because a court order commands it to do so does not always withhold those documents "improperly". Judge, who was supervising a grand jury, issued protective order not at behest of the City (who was holding the records), but upon court's consideration of the need for confidentiality under the circumstances. Attorney fee invoices paid from public funds are generally disclosable under FOIA, subject to redaction for work-product and privilege. Dismissal of portion of complaint that sought disclosure of Office of Special Prosecutor's attorney fee invoices is reversed, and remanded for in camera review of those records pursuant to Seciton 11(f) of FOIA.(HOFFMAN and CUNNINGHAM, concurring.)
Illinois Appellate Court
Civil Court
FOIA