Calloway v. Chicago Police Department

Plaintiff brought suit seeking disclosure of documents related to an officer-involved fatal shooting pursuant to FOIA. The circuit court granted plaintiff’s motion for partial summary judgment holding that the confidentiality provisions of the Juvenile Court Act pertaining to law enforcement records of minors did not apply to deceased minors. The CPD appealed and the appellate court reversed in part and affirmed in part, finding that the circuit court’s conclusion that FOIA’s privacy provisions did not apply “at all” to law enforcement records of deceased minors was incorrect and, as a result, there remained a material issue of fact with respect to whether any of the requested records may be disclosed. The appellate court remanded the matter to the circuit court to conduct further proceedings to determine whether any records may be disclosed without violating the confidentiality provisions applicable to the law enforcement records of minors. (REYES and LAMPKIN, concurring)