Chicago Public Media v. Cook County Office of the President

Plaintiff requested production of records under FOIA relating to a political action committee chaired by a Cook County Commissioner. As to 2 emails containing track edits to the Wikipedia page of the Commissioner, the track edits do not reflect predecisional communications about any substantive governmental policy or actions or about a policy relating to dissemination of information, and relate to factual content on the Commissioner's Wikipedia page. There is no basis for finding communications about the draft answers to a reporter's questions about recent women's marches do not reveal any deliberative process as to any substantive government policy. Defendant failed to meet its burden to show that the challenged redactions pertain to the deliberative process for the development of governmental policy or action relating to dissemination of information and failed to show that the production of the redacted information would reveal the deliberative process for any underlying substantive policy, and thus the deliberative process exemption would not apply. (HOFFMAN and CUNNINGHAM, concurring.)