Green v. City of Chicago

Plaintiff filed a lawsuit seeking to enforce a records request issued under the Freedom of Information Act. The City of Chicago had refused to produce the requested documents under two exemptions contained within the Act. At issue on appeal was whether the circuit court could account for changed circumstances when determining whether the withholding of public information was proper. The Supreme Court adopted a “time-of-request” approach and held that unless the FOIA exemption stated otherwise, the circuit court should review the withholding of information under the circumstances as they existed when the public body made its decision. (ANNE M. BURKE, THEIS, NEVILLE, OVERSTREET, and CARTER, concurring. HOLDER WHITE took no part in the decision.)