Lenard v. Office of the Illinois Secretary of State

2026 IL App (5th) 241062-U
CourtAppellate Court of Illinois
DecidedFebruary 24, 2026
Docket5-24-1062
StatusUnpublished

This text of 2026 IL App (5th) 241062-U (Lenard v. Office of the Illinois Secretary of State) 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
Lenard v. Office of the Illinois Secretary of State, 2026 IL App (5th) 241062-U (Ill. Ct. App. 2026).

Opinion

NOTICE 2026 IL App (5th) 241062-U NOTICE Decision filed 02/24/26. The This order was filed under text of this decision may be NO. 5-24-1062 Supreme Court Rule 23 and is changed or corrected prior to the filing of a Petition for not precedent except in the

Rehearing or the disposition of IN THE limited circumstances allowed the same. under Rule 23(e)(1). APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

CARL LENARD and PRISONER MEDIA-X, ) Appeal from the ) Circuit Court of Plaintiffs, ) Randolph County. ) v. ) No. 23-LA-36 ) THE OFFICE OF THE ILLINOIS SECRETARY OF ) STATE, ) ) Defendant-Appellee ) Honorable ) Lucas H. Liefer, (Carl Lenard, Plaintiff-Appellant). ) Judge, presiding. ______________________________________________________________________________

JUSTICE McHANEY delivered the judgment of the court. Justices Sholar and Hackett concurred in the judgment.

ORDER

¶1 Held: We affirm the circuit court’s order dismissing the plaintiff’s complaint, as he failed to comply with statutory requirements in submitting his Freedom of Information Act requests.

¶2 The plaintiff, Carl Lenard, appeals the July 10, 2024, order of the circuit court of Randolph

County, dismissing his complaint against the defendant, the Office of the Illinois Secretary of State

(ILSOS). For the following reasons, we affirm the dismissal.

¶3 I. BACKGROUND

¶4 On October 17, 2023, Lenard, acting pro se, filed a complaint against the defendant,

ILSOS, alleging violations of the Freedom of Information Act (FOIA) (5 ILCS 140/1 et seq. (West

1 2022)). In addition to naming Lenard as plaintiff, bringing the action on behalf of himself, the

complaint purported to be filed on behalf of “Prisoner Media-X, the nonprofit 501(c)(3)

organization formed by [Lenard] and parent company of Redacted Legal News; a news

publication.”

¶5 The complaint alleged that Lenard submitted requests to ILSOS on behalf of himself and

Prisoner Media-X. Lenard alleged that on or about March 20, 2023, he submitted three individual

letters to ILSOS requesting records for inspection and/or copying, and he mailed his requests via

the United States Postal Service (USPS) to: “Attn: FOIA Officer; 17 North State Street, Suite 1179,

Chicago, Illinois 60602. See exhibits D, E, F, G.” Lenard alleged he sent a follow-up letter to the

same address on or about April 13, 2023. On or about April 28, 2023, Lenard considered the lack

of response from ILSOS to be a denial, so he filed a request for review with the Public Access

Counselor (PAC) of the Office of the Illinois Attorney General. The PAC responded to Lenard,

advising that it had “determined that no further inquiry is warranted.”

¶6 The complaint alleged that Lenard submitted four additional letters to ILSOS on or about

June 27, 2023, with requests to inspect or copy records. He mailed these letters via USPS to: “Attn:

FOIA Officer; 17 North State Street, Suite 1179, Chicago, Illinois 60602. See exhibits I, J, K, L.”

Lenard alleges that ILSOS denied a total of 41 requests in his various letters. He alleged that ILSOS

“willfully, intentionally and/or in bad faith denied his FOIA requests.” Lenard’s request for relief

included an order for ILSOS to provide the requested documents, penalties in the amount of

$205,000 paid to Lenard, and costs of filing suit.

¶7 On February 21, 2024, ILSOS filed a motion to dismiss the complaint pursuant to section

2-619(a)(9) of the Code of Civil Procedure (Code) (735 ILCS 5/2-619 (West 2022)). ILSOS argued

that the complaint should be dismissed because the plaintiffs failed to establish that they properly

2 submitted FOIA requests to ILSOS. This argument was supported by the affidavit of Janna

Spriester, the FOIA officer for ILSOS, who stated that the ILSOS record system did not show

receipt of any FOIA request from Lenard from March 18, 2023, to October 17, 2023. Next, ILSOS

argued that the requests failed to comply with FOIA procedures because they were improperly

addressed. Finally, ILSOS argued that the request for review submitted to the PAC did not

constitute receipt of the request. Further, as to Prisoner Media-X, ILSOS argued that a corporation

may only file a complaint through a licensed attorney, so it should be dismissed as a party. Plaintiff

was granted time to file a written response to the motion to dismiss; however, the record on appeal

does not contain a response.

¶8 On July 10, 2024, the circuit court entered a written order that dismissed the complaint in

its entirety, with prejudice. Lenard filed a timely motion to reconsider the order dismissing the

complaint. Before the motion to reconsider could be ruled upon, Lenard filed a notice of appeal.

The circuit court denied the motion to reconsider on February 6, 2025, which made Lenard’s notice

of appeal effective that day.

¶9 II. ANALYSIS

¶ 10 Lenard argues that the affidavit by Spriester is false and that ILSOS received all FOIA

requests via email on June 7, 2023. Lenard further argues that he did not send the requests to an

improper address, as he sent the requests to the address maintained by the PAC. The ILSOS

responds that the circuit court properly dismissed Lenard’s complaint because Lenard failed to

submit his FOIA requests in compliance with the ILSOS regulations and failed to send them to the

FOIA officer’s designated address as identified on the Secretary’s official forms. As a result,

ILSOS was never in receipt of the requests under the Act, as further established by ILSOS’s

unrebutted affidavit evidence. Finally, ILSOS argues that only individuals who have been denied

3 access to records, meaning that an agency has actually received a request, may bring an action

under section 11 of FOIA (5 ILCS 140/11 (West 2022)). We agree.

¶ 11 Our review of an order granting a motion to dismiss is de novo. Pinkston v. City of Chicago,

2023 IL 128575, ¶ 21. On de novo review, this court may affirm the circuit court’s judgment on

any basis established by the record and law. Funkhouser v. City of Granite City, 2025 IL App (5th)

240666, ¶ 22.

¶ 12 In reviewing a dismissal under section 2-619, this court construes all well-pleaded facts

and makes all reasonable inferences in the plaintiff’s favor. Goral v. Dart, 2020 IL 125085, ¶ 27;

Smith v. Jones, 2025 IL App (5th) 231136, ¶ 19. However, it “disregard[s] all legal and factual

conclusions in the complaint that are not supported by specific factual allegations.” McHenry

Township v. County of McHenry, 2022 IL 127258, ¶ 57. Similarly, “unsupported conclusions,

opinions, or speculation are insufficient to” survive a section 2-619 motion to dismiss.

Northwestern Illinois Area Agency on Aging v. Basta, 2022 IL App (2d) 210234, ¶ 47 (citing Valfer

v. Evanston Northwestern Healthcare, 2016 IL 119220, ¶ 20; Rojo v. Tunick, 2021 IL App (2d)

200191, ¶ 41).

¶ 13 The affirmative matter contemplated in a motion to dismiss must be apparent on the face

of the complaint; otherwise, the motion must be supported by affidavits or other evidentiary

materials. Masters v. Murphy, 2020 IL App (1st) 190908, ¶ 16. A defendant may present

“affidavits or other evidentiary matter” to support an asserted defense under section 2-619(a)(9)

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Zedella v. Gibson
650 N.E.2d 1000 (Illinois Supreme Court, 1995)
Downtown Disposal Services, Inc. v. The City of Chicago
2012 IL 112040 (Illinois Supreme Court, 2012)
Valfer v. Evanston Northwestern Healthcare
2016 IL 119220 (Illinois Supreme Court, 2016)
Goral v. Dart
2020 IL 125085 (Illinois Supreme Court, 2020)
Masters v. Murphy
2020 IL App (1st) 190908 (Appellate Court of Illinois, 2020)
McHenry Township v. County of McHenry
2022 IL 127258 (Illinois Supreme Court, 2022)
Northwestern Illinois Area Agency on Aging v. Basta
2022 IL App (2d) 210234 (Appellate Court of Illinois, 2022)
Harper v. Health Care Service Corp.
2023 IL App (1st) 220078 (Appellate Court of Illinois, 2023)
Pinkston v. City of Chicago
2023 IL 128575 (Illinois Supreme Court, 2023)
Rojo v. Tunick
2021 IL App (2d) 200191 (Appellate Court of Illinois, 2021)
Colon v. Illinois Central R.R. Co.
2024 IL App (1st) 221841 (Appellate Court of Illinois, 2024)
Smith v. Jones
2025 IL App (5th) 231136 (Appellate Court of Illinois, 2025)
Funkhouser v. City of Granite City
2025 IL App (5th) 240666-U (Appellate Court of Illinois, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2026 IL App (5th) 241062-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lenard-v-office-of-the-illinois-secretary-of-state-illappct-2026.