Carrigan v. Harkrader

On May 9, 1985, the plaintiff, Deborah Carrigan, filed suit against the defendant, Peoria County Clerk Mary E. Harkrader, to obtain a copy of the letter which the Peoria County sheriff submitted in conjunction with the plaintiff’s liquor-license application. As an affirmative defense, the defendant denied that the Freedom of Information Act (the Act) (Ill. Rev. Stat. 1985, eh. 116, par. 201 et seq.), authorized the plaintiff’s request and alternatively argued that the letter was exempt from disclosure.

After inspecting the letter in camera, the court denied the plaintiff’s request for…