Taylor v. Cook County State’s Attorney’s Office

Plaintiff filed a lawsuit after his request for records under the Freedom of Information Act was denied by the defendant on the basis that their disclosure would interfere with pending law enforcement proceedings. Plaintiff appealed and argued that defendant failed to prove the requested records were exempt. The appellate court reversed and remanded, ordering defendant to comply with its burden under FOIA to produce the requested documents or justify application of the exemption by preparing an index and detailed affidavit explaining why disclosure of each document would interfere with pending or reasonably contemplated law enforcement proceedings. (TAILOR and GAMRATH, concurring)