Garlick v. Bloomingdale Township

Illinois Appellate Court
Civil Court
FOIA
Citation
Case Number: 
2018 IL App (2d) 171013
Decision Date: 
Thursday, September 6, 2018
District: 
2d Dist.
Division/County: 
Du Page Co.
Holding: 
Affirmed.
Justice: 
JORGENSEN

Plaintiff sought, under FOIA, an electronic copy of all publicly disclosable data within Township's property-assessment software system, in its native file format. Township provided certain data to Plaintiff, but Plaintiff filed complaint alleging that data was not provided in format he had requested. Plaintiff concedes that data Township provided to him two days after he filed complaint was fully responsive to his FOIA request. Thus, court properly dismissed complaint as moot, as there is no controversy as to data requested. Court properly imposed sanctions against Plaintiff for filing a frivolous complaint. (ZENOFF and SCHOSTOK, concurring.)