Mancini Law Group, P.C. v. Schaumburg Police Department
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Mancini Law Group sent a commercial Freedom of Information Act (FOIA) request (5 ILCS 140/1) to the Schaumburg Police Department seeking disclosure of all traffic accident reports for all motor vehicle accidents that occurred within the Village between June 30, 2017, and July 13, 2017. The Department provided redacted accident reports, asserting that FOIA section 7(1)(b) exempted driver’s license numbers, personal telephone numbers, home addresses, and personal license plates; the Department relied upon section 7(1)(c) in redacting dates of birth and policy account numbers. The names of drivers and witnesses were unredacted.
The circuit court held that the Department had established that the information at issue was exempt and rejected Mancini’s argument that the Department was precluded from asserting that the information was exempt because it voluntarily provided unredacted traffic accident reports to LexisNexis, a third-party vendor approved by the state for assisting the Department with its Illinois Vehicle Code mandatory reporting obligations.
The Illinois Supreme Court affirmed. The Department is not precluded from asserting that the redacted information is exempt under sections 7(1)(b) and 7(1)(c). An Illinois public body does not have the ability to waive an individual’s interest in his personal or private information that is contained in a document subject to a FOIA request. it is irrelevant whether the Department could have chosen to fulfill its mandatory reporting obligations in a different way.
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