City of Champaign v. Madigan

City of Champaign v. Madigan
City of Champaign v. Madigan
	Fourth District Appellate Court building in Springfield, Illinois
Court	Illinois Appellate Court, Fourth District
Full case name	The City of Champaign v. Lisa Madigan, Attorney General of the State of Illinois; Patrick Wade; and The News-Gazette, Inc.
Decided	July 16, 2013
Citation(s)	2013 IL App (4th) 120662; 992 N.E.2d 629 (2013)
Case history
Prior action(s)	Attorney General, Public Access Opinion 11-006
Appealed from	Circuit Court of Sangamon County, No. 11-MR-680; John Schmidt, Judge, presiding
Court membership
Judges sitting	Carol Pope, Thomas R. Appleton, Lisa Holder White
Case opinions
	Electronic communications during city council meetings and pertaining to public business are subject to disclosure under the Freedom of Information Act, regardless of whether they are stored on personal devices.
Decision by	Pope, joined by Appleton, Holder White

City of Champaign v. Madigan, 2013 IL App (4th) 120662, 992 N.E.2d 629 (2013), is a case decided by the Illinois Appellate Court in 2013 concerning the state's Freedom of Information Act (FOIA). The court ruled that messages sent and received by elected officials during a city council meeting and pertaining to public business are public records subject to disclosure, even when those communications are stored on personal electronic devices. It was the first court ruling in Illinois to hold that private messages were subject to public disclosure under FOIA.

The case addressed a public records request from a reporter for The News-Gazette in Champaign, Illinois, who observed Champaign city council members and the mayor using their personal electronic devices to send messages during a city council meeting. City officials denied the reporter's request for disclosure of the private messages. The case eventually reached the Appellate Court, which held that public officials have to disclose their records, even if they are stored on a personal electronic device or account, but only when acting as a public body. The court found that members of a city council do not constitute a public body when acting individually. However, because the city council members in question had convened a public meeting, they were acting collectively as a public body, and their messages were therefore subject to disclosure under FOIA.