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Tuesday, August 25, 2026

Court Finds Appeal of Dismissal of FOIA Lawsuit Frivolous


An Illinois Appellate Court ruled in favor of a public body in a FOIA lawsuit, finding the appeal frivolous in Tidwell v. Illinois Department of Corrections.

A requester submitted a request to the Illinois Department of Corrections (IDOC) seeking the names of all medical personnel. IDOC denied the request, citing to a FOIA exemption that expressly exempts from release records requested by persons committed to the DOC or a county jail that include staff members' personnel files, staff rosters, or other staffing assignment information. The requester filed a lawsuit against IDOC. The circuit court dismissed his lawsuit, ruling in favor of IDOC. He then appealed to the Illinois Appellate Court.

The Appellate Court upheld the circuit court's dismissal of his lawsuit, finding that his appeal of the circuit court's decision was frivolous because he was aware of the specific exemption that prevented the disclosure of the information he requested. 




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