Case Involving Conclusory and Inadequate Affidavits

In Day v. City of Chicago, 388 Ill. App. 3d 70, 902 N.E.2d 1144, 327 Ill. Dec. 758 (2009), the Court held that affidavits submitted by Sandoval and Gibson were entirely conclusory and inadequate to sustain the city's burden to show that the requested documents were exempt. Day, 388 Ill. App. 3d at 75, 902 N.E.2d at 1149. the case was remanded and the circuit court was directed to conduct an in camera review of the documents in order to determine whether the law enforcement or privacy exemptions applied. Day, 388 Ill. App. 3d at 80, 902 N.E.2d at 1153.