1 v. Board of Education of Lake Forest High School District 115

2024 IL App (2d) 230173
CourtAppellate Court of Illinois
DecidedMay 30, 2024
Docket2-23-0173
StatusPublished

This text of 2024 IL App (2d) 230173 (1 v. Board of Education of Lake Forest High School District 115) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
1 v. Board of Education of Lake Forest High School District 115, 2024 IL App (2d) 230173 (Ill. Ct. App. 2024).

Opinion

2024 IL App (2d) 230173 No. 2-23-0173 Opinion filed May 30, 2024 ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT ______________________________________________________________________________

PLAINTIFF 1, PLAINTIFF 2, and ) Appeal from the Circuit Court PLAINTIFF 3, ) of Lake County. ) Plaintiffs-Appellants, ) v. ) No. 22-LA-540 ) THE BOARD OF EDUCATION OF LAKE ) FOREST HIGH SCHOOL DISTRICT 115, ) Honorable ) Charles W. Smith, Defendant-Appellee. ) Judge, Presiding. ______________________________________________________________________________

JUSTICE SCHOSTOK delivered the judgment of the court, with opinion. Justices Hutchinson and Birkett concurred in the judgment and opinion.

OPINION

¶1 The plaintiffs, who have taken pains to shield their identities, sued the defendant, the Board

of Education of Lake Forest High School District 115 (Board), for disclosing private information

and details of their settlement of a prior lawsuit against the Board despite a confidentiality

provision in that settlement agreement (Agreement). In April 2023, the trial court dismissed the

suit pursuant to section 2-615 of the Code of Civil Procedure (Code) (735 ILCS 5/2-615 (West

2022)). The plaintiffs appeal. We affirm in part, reverse in part, and remand for further

proceedings. 2024 IL App (2d) 230173

¶2 I. BACKGROUND

¶3 The following facts are drawn from the exhibits and the allegations of the complaint,

which, at this point, we must take as true. Cahokia Unit School District No. 187 v. Pritzker, 2021

IL 126212, ¶ 24.

¶4 In 2016, the plaintiffs—a student in a school governed by the Board (Student Plaintiff) and

the Student Plaintiff’s parents—sued the defendant, alleging that the defendant had denied the

Student Plaintiff a free and appropriate public education by failing to provide the Student Plaintiff

with necessary accommodations for the Student Plaintiff’s disability (Underlying Suit). When it

proceeded to federal court, the suit was filed using the plaintiffs’ initials only under Federal Rule

of Civil Procedure 5.2(a)(3) (Fed. R. Civ. P. 5.2(a)(3) (requiring the use of initials to refer to

minors); see Steven S. Gensler, Fed. R. Civ. P. 5.2(a)(3), Rules and Commentary (Feb. 2024

Update) (noting that parents are often permitted to file using initials only as well, to further protect

minors’ identities)). According to the complaint in the present case, the Underlying Suit involved

disclosures of the Student Plaintiff’s “physical, emotional, and psychological disabilities in vivid

detail, including reports, and expert witness testimony.”

¶5 In the spring of 2022, the parties agreed to settle the Underlying Suit. In return for the

defendant’s payment of a certain sum, the plaintiffs agreed to dismiss all of the ongoing

proceedings against the defendant. The Agreement was prepared, and it includes, among its terms,

the following provisions:

“3. Confidentiality. This Agreement and any and all matters referred to herein or

concerning this Agreement shall be regarded as strictly confidential and not to be disclosed

to third parties, except to a Party’s accountant, auditor, attorney, or as required by law.

Nothing herein shall prevent any Party from responding to a lawful subpoena, reporting to

-2- 2024 IL App (2d) 230173

IRS, complying with any other legal obligation, or acting in an action alleging breach or

enforcing the terms of this Agreement.

***

5. Mutual Non-Disparagement; Party Statements. The Parties agree that they shall not

make any disparaging or derogatory statements concerning each other or the Released

Parties and/or any matters encompassed in the Lawsuit that may have an adverse effect on

the Released Parties’ reputation or business interests; provided, however, that nothing in

this Section shall prevent either Party from testifying truthfully in connection with any

litigation, arbitration or administrative proceeding when compelled by subpoena,

regulation or court order to do so.”

The Agreement identifies the parties by their full names and listed the district court docket number.

The complaint alleges that, armed with this information, anyone could access the full court file of

the Underlying Suit.

¶6 Despite the Agreement’s terms, both prior to and after the execution of the Agreement, the

defendant published the Agreement on a variety of dates and in several ways. In August 2022,

after the plaintiffs learned of some of the publications of the Agreement, their attorney requested

documents related to the Agreement pursuant to the Freedom of Information Act (FOIA) (5 ILCS

140/1 et seq. (West 2020)). The plaintiffs include, as exhibits to the complaint, several of the

responsive documents, which the defendant partially redacted prior to producing them. The

complaint alleges the following disclosures of the Agreement.

¶7 On June 2, 2022, at about noon, Tiana Adams, the executive assistant to the defendant’s

superintendent and clerk of the Board, sent an e-mail titled “For Review – D115 Agenda 06.14.22.”

The e-mail sought approval of an attached agenda before it was sent to “Board presidents.” The

plaintiffs allege that, upon information and belief, the attachment (which was not included in the

-3- 2024 IL App (2d) 230173

FOIA response) related to the upcoming June 14, 2022, Board meeting at which the Agreement

would be presented for approval, and it included a copy of the complete and unredacted

Agreement.

¶8 That evening, Deputy Superintendent Jeff McHugh responded twice to Adams’s e-mail,

once at 8:29 p.m. and again at 10:35 p.m. In his first e-mail, McHugh simply stated, “Looks good

to me.” (Any earlier attachment was not included in the FOIA response.) In his second e-mail,

McHugh included his own attachment (also not produced in the FOIA response), which was titled

“Lake Forest HSD 115 v. ISBE and [redacted] Settlement Agreement (3026212.1).docx.” In this

second e-mail, McHugh said that he was “just confirming that the first action time [sic] is regarding

the attached document [redacted] settlement” and that “[w]e wanted to add this as an action item”

but he was not sure whether that was what the first item was.

¶9 On June 10, 2022, at about 3:21 p.m., “District 115 Communications” e-mailed to unknown

members of the public a notice of the June 14, 2022, school board meeting. The e-mail contained

a link to an online webpage that was publicly accessible and contained further links to the agenda

for the meeting and to a complete, unredacted copy of the Agreement. The link to the Agreement

permitted members of the public to view, copy, download, print, circulate, and otherwise possess

the unredacted Agreement, including the plaintiffs’ full names and the docket number of the

Underlying Suit.

¶ 10 About an hour after the posting of this meeting notice, someone e-mailed back to “District

115 Communications,” saying, “you should take out or redact the actual settlement with the

[redacted] Family that is accessible through the meeting agenda. I would think this is a violation

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Bluebook (online)
2024 IL App (2d) 230173, Counsel Stack Legal Research, https://law.counselstack.com/opinion/1-v-board-of-education-of-lake-forest-high-school-district-115-illappct-2024.