An inmate at a correctional center made several FOIA requests to the Illinois Department of Corrections (IDOC) seeking his medical records and copies of administrative rules. IDOC initially denied the requests for medical records because the inmate failed to follow IDOC’s administrative policy. IDOC also initially denied the inmate’s copies for certain administrative rules based on FOIA exemptions.

The inmate sued IDOC alleging that (1) his medical records were withheld in violation of FOIA and (2) that the inmate was entitled to recover costs and penalties. The circuit court dismissed the inmate’s lawsuit, finding that the inmate’s medical records were exempt from disclosure until the inmate eventually followed IDOC’s administrative procedures and that the inmate was not entitled to penalties and costs. The court also directed IDOC to provide updated copies of the administrative rules originally requested by the inmate because the inmate was being relocated to another facility that did not possess copies of the updated administrative rules at issue. On appeal, the inmate solely claim that the circuit court erred by denying his request for fees and costs under FOIA.

In Watson v. Illinois Department of Corrections, the Appellate Court upheld the circuit court’s denial of fees and costs to the inmate, finding that the inmate did not prevail in his lawsuit. The Appellate Court noted that the circuit court granted IDOC’s motion to dismiss because the inmate was not entitled to the requested medical records under FOIA, which is an adverse judgment against the inmate. Although the circuit court had directed IDOC to produce updated copies of certain administrative rules, the Appellate Court clarified that the circuit court had denied the inmate’s claim that he was entitled to these documents on its merits. As a result, the Appellate Court upheld that circuit court’s decision to deny the inmate’s request for costs under FOIA section 11(i).

Post Authored by Eugene Bolotnikov, Ancel Glink