Donley v. City of Springfield

Plaintiff filed a complaint for declaratory judgment and injunctive relief alleging violations of the Freedom of Information Act and sought civil penalties, attorney fees, and costs. The city produced some of the documents while the action was pending and the trial court subsequently granted judgment in favor of the city but awarded the plaintiff attorney fees and costs as the prevailing party. The appellate court reversed the order awarding attorney fees and costs, finding that the lawsuit was not necessary to obtain the documents where plaintiff had failed to provide the city with sufficient information to determine whether the documents were subject to disclosure under FOIA. (HARRIS and BRIDGES, concurring)