When the FOIA Clock Starts: Illinois Court Clarifies When Electronic Requests Are Received
by Hayley Loufek An Illinois Appellate Court recently clarified when the statutory response period under the Freedom of Information Act (“FOIA”) begins for electronically submitted requests. In Balzer v. Northeast Illinois Regional Commuter Railroad Corporation, 2026 IL App (1st) 232227, the court held that a FOIA request is “received” when it enters a public body’s email system—not when personnel first …
