Case Summary

This matter challenges the Illinois Attorney General's August 28, 2026 determination that two separate FOIA requests submitted on August 21, 2026 constitute a "voluminous request." The requests sought, respectively, generally applicable PAC guidance concerning electronic and system-generated records, and PAC matters involving Flock Safety/ALPR records.

The Attorney General determined that the two requests, when combined, seek more than five categories of records and require compilation of more than 500 pages. The Request for Review asks the Public Access Counselor to determine whether those statutory thresholds were properly applied, whether the Office adequately explained the basis for its determination, and whether its voluminous-request notice complied with the mandatory requirements of section 3.6(a) of FOIA.

Grounds for Review

The grounds for review are whether the Attorney General properly classified the two August 21, 2026 FOIA requests as a voluminous request under sections 2(h) and 3.6 of FOIA. Specifically, the request challenges the Office's failure to explain how the two requests constitute more than five different categories of records, the factual basis and methodology for concluding that responsive records exceed 500 pages, and whether the August 28 notice satisfied all mandatory notification requirements of section 3.6(a).