Uptown People’s Law Center v. The Department of Corrections 

(Court opinion corrected 2/27/14.) Plaintiff alleged that IDOC failed to turn over public records in violation of FOIA. After suit filed, IDOC provided requested records, and court dismissed action as moot. Court-ordered relief is not a prerequisite to an award of attorney fees under FOIA. A not-for-profit legal organization is prohibited from being awarded legal fees that were not actually incurred in pursuing a FOIA request on the organization's behalf. (HOWSE and FITZGERALD SMITH, concurring.)