Illinois Appellate Court
Civil Court
Freedom of Information Act
Plaintiff appealed from a circuit court order dismissing her Freedom of Information Act complaint against the defendants, arguing that the circuit court abused its discretion when it appointed a special master and required the plaintiff to pay for the services of the appointed master for an in camera review. The appellate court agreed, noting that nothing within the language of the Freedom of Information Act authorizes a circuit court delegate the court’s statutory authority to resolve disputes relating to request for public records or to condition judicial review on a requester’s payment of additional costs. (BOIE and McHANEY, concurring)