Chicago Sun-Times v. Cook County Health and Hospital System

Summary

The court held that the requested years of patient admission and law-enforcement notification were not exempt from disclosure under either HIPAA-related FOIA provisions or FOIA's private-information exemption, provided identifying information was removed. The year element could be retained during HIPAA de-identification because it is not an identifier that must be removed, and the year alone is not a medical record under the ordinary meaning of that term. The court affirmed the appellate judgment, reversed the circuit court judgment, and remanded for further proceedings.