Chapman v. Chicago Department of Finance

Summary

The court held that FOIA section 7(1)(o) creates a per se exemption for file layouts, without requiring a public body to prove that disclosure would jeopardize system security. Because the requested index of database tables, columns, and data types constituted a file layout, the records were exempt from disclosure. The court reversed the lower-court judgments and remanded for entry of judgment in favor of the Department of Finance.