Mohammad v. Chicago Police Department

2020 IL App (1st) 190011-U
CourtAppellate Court of Illinois
DecidedJune 30, 2020
Docket1-19-0011
StatusUnpublished

This text of 2020 IL App (1st) 190011-U (Mohammad v. Chicago Police Department) 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
Mohammad v. Chicago Police Department, 2020 IL App (1st) 190011-U (Ill. Ct. App. 2020).

Opinion

2020 IL App (1st) 190011

SIXTH DIVISION June 30, 2020

No. 1-19-0011

NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(e)(1).

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

MANSOUR MOHAMMAD, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Cook County. ) v. ) No. 17 CH 16963 ) THE CHICAGO POLICE DEPARTMENT, ) Honorable ) Peter Flynn, Defendant-Appellee. ) Judge Presiding.

PRESIDING JUSTICE MIKVA delivered the judgment of the court. Justices Connors and Harris concurred in the judgment.

ORDER

¶1 Held: Where plaintiff failed to show that there was a genuine issue of material fact as to whether defendant complied with his FOIA request, the circuit court’s grant of summary judgment in favor of defendant is affirmed.

¶2 Plaintiff, Mansour Mohammad, appeals from the circuit court’s grant of summary

judgment in favor of defendant, the Chicago Police Department (CPD), finding that no genuine

issue of material fact existed as to whether the CPD complied with Mr. Mohammad’s request under

the under the Illinois Freedom of Information Act (FOIA) (5 ILCS 140/1 et seq. (West 2016)). On No. 1-19-0011

appeal, Mr. Mohammad argues that this grant of summary judgment was in error because (1) the

CPD has not fully discharged its obligation to him under FOIA, (2) the documents that the CPD

provided to Mr. Mohammad were improperly redacted, (3) the CPD intentionally violated FOIA

in bad faith and therefore should incur civil penalties, and (4) there is outstanding discovery

material relating to a genuine factual issue. For the following reasons, we affirm.

¶3 I. BACKGROUND

¶4 The following chronology is taken from Mr. Mohammad’s complaint, the CPD’s motion

for summary judgment, Mr. Mohammad’s response to that motion, and relevant attachments to

those filings.

¶5 In September 2016, Mr. Mohammad filed a FOIA request with the CPD, asking for all

police reports for case No. 09 CR 08678. The CPD responded on September 28, 2016, providing

60 pages of responsive records. On October 26, 2016, Mr. Mohammad filed another FOIA request

with the CPD, specifically asking for “all inventory reports, general progress reports, general

offense case reports, investigative reports, patrol division canvass worksheets, supplementary

reports, written notes, written statements, not limited to, but including all responsive records

prepared by or for, or used by, received by, in the possession of, or under the control of any public

body,” and “any and all emails relating to” case No. 09 CR 8678.

¶6 After requesting multiple extensions, on December 27, 2016, Officer Gary Rubenstein, a

CPD FOIA officer, responded to Mr. Mohammad’s second request. In the letter accompanying the

response, Officer Rubenstein indicated that his request was interpreted “to be for the Bureau’s

Area Investigative File,” and that the CPD was releasing 242 pages of responsive records. He

further stated that “[s]hould specific information listed in our request not be found in this record,

it means that CPD has no responsive record for that specific request.” Officer Rubenstein also

2 No. 1-19-0011

stated that the 242 pages had been redacted pursuant to sections 7(1)(b), (c), and (d) of FOIA (5

ILCS 140/7(1)(b), (c), (d) (West 2016)), and listing the specific types of information that had been

redacted and why.

¶7 Mr. Mohammad requested review of his FOIA request by the public access counselor at

the Illinois Attorney General’s Office, explaining that he did not receive all of the responsive

records he requested. A representative of the Public Action Bureau (PAB) sent a letter to the

general counsel of the CPD, asking the CPD to “provide detailed written explanation of why CPD

construed the request as limited to the Area Investigative File and whether CPD possesses the

records Mr. Mohammad identified as missing from his Request for Review.” The CPD did not

respond.

¶8 On July 20, 2017, the PAB representative wrote to both the general counsel of the CPD

and to Mr. Mohammad, stating in part that “although it [wa]s unclear whether CPD possesses the

records Mr. Mohammad claims he should have received,” the CPD’s lack of response to the PAB

inquiry “did not demonstrate that it conducted a reasonable search for the responsive records.” She

thus found that the CPD had violated the requirements of FOIA. She also stated, however, that

resolution of the matter did not require “the issuance of a binding opinion” and the letter served to

close the matter.

¶9 No further action was taken with respect to this FOIA request by any party until December

26, 2017, when Mr. Mohammad filed his FOIA complaint against the CPD in the circuit court

requesting that the CPD be (1) enjoined from withholding the records he requested, (2) ordered to

fully release the requested records, and (3) civilly penalized for between $2500 and $5000 under

section 11 of FOIA (5 ILCS 140/11 (West 2016)), for acting in bad faith or willfully or

intentionally failing to comply with FOIA.

3 No. 1-19-0011

¶ 10 On August 14, 2018, the CPD filed its motion for summary judgment. In it, the CPD argued

it was entitled to summary judgment because (1) it had fully discharged its obligations under FOIA

by providing Mr. Mohammad with the records that were responsive to his request, (2) any

redactions made were permitted by FOIA, and (3) no civil penalty was appropriate since it did not

violate FOIA. The CPD attached to that motion an affidavit from Officer Rubenstein, in which he

attested that he had been the CPD FOIA officer since July 2016, that the FOIA officer has the

responsibility of “reviewing, analyzing and responding to” FOIA requests, that upon receipt of a

FOIA request he “analyze[s] the plain language of the request to determine if CPD maintains the

documents requested and if so, whether CPD is still in possession of the requested records and

finally, whether any portions of those records are exempt from disclosure pursuant to available

FOIA exemptions.” Officer Rubenstein stated that he was the officer originally assigned to Mr.

Mohammad’s FOIA request and that he noted the records Mr. Mohammad was requesting

concerned his murder case and that, in his experience as the CPD FOIA officer, “when a FOIA

request concerns major crimes, like [Mr. Mohammad’s] murder case, the documentation will be

found with the Detectives Division.” Officer Rubenstein explained that each case is identified with

a unique Records Division (RD) number and he learned the RD number associated with Mr.

Mohammad’s case was HP445128. He then requested the “full Investigative File” associated with

that RD number from the Bureau of Detectives. After redacting information exempt from release

under FOIA, Officer Rubenstein “forwarded copies of the 242 pages of responsive records to Mr.

Mohammad.”

¶ 11 Also attached to the CPD’s summary judgment motion was the request that Officer

Rubenstein sent to the Bureau of Detectives and the response from the chief of the Bureau of

Detectives. In his request, Officer Rubenstein asked for records that “relate[d] to a 2009 homicide

4 No. 1-19-0011

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

Related

James Miller v. United States Department of State
779 F.2d 1378 (Eighth Circuit, 1986)
David Carney v. United States Department of Justice
19 F.3d 807 (Second Circuit, 1994)
Illinois Education Ass'n v. Illinois State Board of Education
791 N.E.2d 522 (Illinois Supreme Court, 2003)
BlueStar Energy Services, Inc. v. Illinois Commerce Commission
871 N.E.2d 880 (Appellate Court of Illinois, 2007)
Chicago Alliance for Neighborhood Safety v. City of Chicago
348 Ill. App. 3d 188 (Appellate Court of Illinois, 2004)
Perry v. Department of Financial & Professional Regulation
2018 IL 122349 (Illinois Supreme Court, 2018)
Monson v. City of Danville
2018 IL 122486 (Illinois Supreme Court, 2019)
Beaman v. Freesmeyer
2019 IL 122654 (Illinois Supreme Court, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
2020 IL App (1st) 190011-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mohammad-v-chicago-police-department-illappct-2020.