Chapman v. Chicago Department of Finance

In a Freedom of Information Act action, defendant appealed from an order of the trial court finding that the defendant violated FOIA by failing to disclose records requested by the plaintiff. On appeal to the Supreme Court, the defendant argued that the records were exempted under section 7(1)(o) of the FOIA and that disclosure of the records would jeopardize the security of its system. The Supreme Court reversed and remanded, holding that the requested records, which were an index of the tables and columns used by the defendant in a records database, were “file layouts” within the meaning of section 7(1)(o) and were exempt from disclosure. (THEIS, NEVILLE, OVERSTREET, CUNNINGHAM, ROCHFORD, and O’BRIEN, concurring)