Illinois Supreme Court

Green v. Chicago Police Department

September 22, 2022465 Ill. Dec. 309

Summary

The court held that a FOIA denial must ordinarily be evaluated based on the circumstances existing when the public body made its decision, rather than circumstances arising during later litigation. Because a lawful injunction barred disclosure when the Chicago Police Department constructively denied the request, the injunction's later vacatur did not make the original withholding improper. The court affirmed the appellate court and reversed the circuit court.