Turner v. Joliet Police Department

Illinois Appellate Court
Civil Court
FOIA
Citation
Case Number: 
2019 IL App (3d) 170819
Decision Date: 
Monday, January 7, 2019
District: 
3d Dist.
Division/County: 
Will Co.
Holding: 
Affirmed.
Justice: 
O'BRIEN

Plaintiff filed filed declaratory and injunctive relief against Police Department, alleging that Department claimed inapplicable exemptions in responding to his FOIA document request. Court properly dismissed Plaintiff's claims with prejudice. Because Plaintiff now has received all the requested documents, his claims are moot. Department correctly relied on Rule 415(c) as basis for exemption limiting disclosures prohibited under state rules. Plaintiff failed to sufficiently allege Department's willful and intentional noncompliance with FOIA request to warrant a civil penalty. (LYTTON and WRIGHT, concurring.)