Last month, we told you about a new set of FOIA requests we filed with the Chicago Department of Law, seeking records on how the City tracks, analyzes, and pays for litigation involving the Chicago Police Department. We asked for internal litigation analyses, the databases and systems the City uses to manage CPD lawsuits, records on settlement and judgment payments, and documentation of how the Department searches for records in response to FOIA requests in the first place.
We laid out specific, named documents. We cited the City’s own Office of Inspector General report. We gave the Department exact titles, exact database names, exact paragraph numbers from the Consent Decree. This was about as targeted as a FOIA request gets.
Here’s how the Department of Law responded.
Four Requests, Four Letters, Six Minutes
On August 27, 2026, right at the edge of the statutory five-business-day response window under 5 ILCS 140(3), the Department of Law’s FOIA office sent us four separate denial letters, one for each of our four requests (FOIA A, B, C, and D). Here’s when each one landed in our inbox:
- F149675-082426 (Request A, internal litigation analyses): 2:42 PM
- F149678-082426 (Request B, litigation databases and tracking systems): 2:44 PM
- F149680-082426 (Request C, settlement and judgment payments): 2:46 PM
- F149681-082426 (Request D, records of the Department’s search efforts): 2:48 PM
Four letters. Six minutes. Every single one denies the request and demands that we “narrow and clarify” it, using nearly word-for-word identical legal boilerplate in all four.
The Same Paragraph, Copied and Pasted Four Times
Read the letters side by side and you’ll find the same block of text reproduced verbatim in every response, regardless of what was actually being requested:
“Your Requests A through D for ‘all records’ concerning various matters spanning more than ten years do not sufficiently identify the records you are seeking and are therefore burdensome.”
That sentence appears in every one of the four letters, including the letter denying Request D, which wasn’t a request for “all records” spanning categories A through D at all. Request D asked for four narrow, concrete things: where the Department searched, who searched, who was asked to produce records, and what records were located but withheld. It’s a request about the Department’s own internal process, not a request for a decade of litigation data. The Department denied it anyway, using the same template built for a completely different request.
That’s not a legal analysis. That’s a form letter with the serial numbers left on.
Calling Named Databases “Unidentifiable”
The most telling example is the response to Request B, which asked for records identifying the databases and Electronic Litigation Management systems the Department uses to track CPD litigation. We didn’t ask the Department to guess. We named the systems ourselves, straight from the City’s own Office of Inspector General report: TeamConnect and CounselLink.
The Department’s response claims it cannot “determine precisely what records are being requested,” about a request that names the exact software platforms, sourced from an official City watchdog report, that the Department is known to use for this exact purpose. If a report commissioned by the City can name these systems, the Department of Law identifying records about its own software is not an undue burden. It’s Tuesday.
Denying a Request for Documents That Already Exist
Request A specifically asked for the “Report on Chicago Police Department 2019 Litigation,” a document cited by title, with footnote numbers, in the OIG’s own report on CPD litigation risk management. This isn’t a request asking the Department to create something new; it’s a request for a report the City’s own oversight office has already confirmed exists.
The Department’s denial leans on Kenyon v. Garrels for the principle that FOIA doesn’t require an agency to create new documents. That case law is irrelevant here. Nobody asked the Department to create a report. We asked for one that, according to the City’s own Inspector General, already sits in a file somewhere.
“Unduly Burdensome,” According to Whom?
Illinois law does allow an agency to deny a request as unduly burdensome, but only if it can show that compliance would create a genuine burden that outweighs the public interest, and only after making a genuine, good faith attempt to work with the requester to narrow it. 5 ILCS 140/3(g) is not a magic phrase. It requires actual analysis of volume, actual identification of what’s overbroad, and an actual conversation about what a workable request would look like.
Instead, the Department:
- Never estimated how many records, emails, or pages might be responsive
- Never identified which specific parts of the request were the problem, as opposed to which parts (like the named reports, named spreadsheet, and named databases) were already about as specific as language allows
- Gave us fourteen days to guess at a “narrower” version of a request that already named specific documents, systems, and paragraph numbers
- Threatened outright denial if we didn’t resubmit in writing, without engaging with a single substantive detail of what we asked for
If the Department genuinely reviewed each of these four requests on its own terms, it’s a remarkable coincidence that all four reviews reached identical legal conclusions, in the same boilerplate language, four minutes apart.
Why This Matters
Chicago taxpayers have paid out hundreds of millions of dollars over the years to resolve lawsuits involving CPD officers and employees. The public has every right to know how the City tracks that liability, what data systems exist to manage it, and whether any of that data is actually being used to prevent future misconduct, or just quietly processed and paid out.
A form letter denial, sent within minutes for every request regardless of subject matter, isn’t a genuine review of a records request. It’s an attempt to make the request disappear through delay and boilerplate, in the hope that requesters won’t push back.
We will. We’re evaluating our options under the Act, including review by the Illinois Attorney General’s Public Access Counselor, and we’ll continue to report on what happens next.
Meaningful accountability requires meaningful transparency. Four identical denial letters in six minutes is not transparency. It’s a form letter wearing a lawyer’s signature.
