City of Champaign v. Madigan is a 2013 case decided by the Appellate Court of the US state of Illinois, ruling that messages sent and received by elected officials during a city council meeting and pertaining to public business are public records subject to disclosure, even when stored on personal electronic devices. It was the first court ruling in Illinois to hold that private messages were subject to disclosure under the state's Freedom of Information Act. The case addressed a public records request from a reporter for The News-Gazette in Champaign, Illinois, who observed city council members and the mayor using their personal electronic devices to send messages during a city council meeting. City officials denied the reporter's request; the case eventually reached the Appellate Court, which held that public officials have to disclose their records, even if they are stored on a personal electronic device or account, but only when acting as a public body, such as during a council meeting. (Fullarticle...)
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