Wikipedia:Featured article candidates/City of Champaign v. Madigan/archive1

The following is an archived discussion of a featured article nomination. Please do not modify it. Subsequent comments should be made on the article's talk page or in Wikipedia talk:Featured article candidates. No further edits should be made to this page.

The article was promoted by FrB.TG via FACBot (talk) 16 February 2024 [1].

---

City of Champaign v. Madigan

Nominator(s): Edge3 (talk) 04:45, 21 January 2024 (UTC)

City of Champaign v. Madigan is an Illinois court case interpreting the state’s public records law. After a city council meeting in Champaign, Illinois, during which public officials were sending private messages on their personal electronic devices, a journalist asked for copies of those communications. The city denied the request, and the case worked its way through administrative review and the courts. The Illinois Appellate Court ordered the release of the records, and the decision was the first in Illinois to hold that private messages were subject to public disclosure. Edge3 (talk) 04:45, 21 January 2024 (UTC)

MyCatIsAChonk

Marking a spot- hope to review in the next week or so! Please do ping me if I forget MyCatIsAChonk (talk) (not me) (also not me) (still no) 13:11, 21 January 2024 (UTC)

Here we are:

• Note period placements after quotes: responding that "private citizen's communications to the Council member's or the Mayor's privately owned electronic devices is not within the scope of the Freedom of Information Act." is shortly followed by were each communicating "in their role as a member of that public body during an ongoing public meeting". Make sure it's consistent throughout and with other quotes ahead; be mindful of MOS:QUOTEPUNCT

  I think the example you gave above is correct because quoted sentence fragments do not include the period, while complete sentences do. See MOS:INOROUT. If you have additional thoughts on this, let me know. Edge3 (talk) 15:59, 26 January 2024 (UTC)

• Frank LoMonte, of the Student Press Law Center, regarded - are commas needed?

  Commas removed. Edge3 (talk) 15:59, 26 January 2024 (UTC)

• The bill also would have required public officials - which bill? Two were mentioned in the previous sentence, clarify with "The first/second/former/latter bill..."

  Clarified. Edge3 (talk) 15:59, 26 January 2024 (UTC)

I got nothing else, Gog got a lot of the grammar stuff and it's overall well-written as is. Great job! MyCatIsAChonk (talk) (not me) (also not me) (still no) 01:27, 26 January 2024 (UTC)

Thanks so much for your feedback! Edge3 (talk) 15:59, 26 January 2024 (UTC)

Support, excellent work! MyCatIsAChonk (talk) (not me) (also not me) (still no) 00:14, 29 January 2024 (UTC)

Support from Gog the Mild

Recusing to review. Some initial thoughts.

• The lead is (very) long in proportion to the length of the article, and at four paragraphs does not align with MOS:LEADLENGTH]]. (Suggest, at least for starters, scrapping the whole of the last paragraph and the last sentence of the third.)
• "City of Champaign v. Madigan, 2013 IL App (4th) 120662, 992 N.E.2d 629 (2013)". "an acronym should be written out in full the first time it is used on a page, followed by the abbreviation in parentheses", just checking that none of that applies here?
• "Attorney General" at first mention in the lead should be "Illinois Attorney General" and be linked. Consider also "Illinois Attorney General" in the image caption.
• "The court ruled that messages sent and received by elected officials during a city council meeting". Consider adding "and pertaining to public business".
• "outside the public's view", Well, the sending wasn't, and that the content of the messages was seems so obvious as to not need mentioning.

More to follow. Gog the Mild (talk) 18:57, 21 January 2024 (UTC)

I've shortened the lead to two paragraphs and made other copyedits as you suggested. See this edit. As for the abbreviations, MOS:LAW says that I should cite cases according to the generally accepted citation style for the relevant jurisdictions, which in this case is the Bluebook, and specifically within Illinois state courts, citations to the Illinois Appellate Court's public domain reporter are preferred over the North Eastern reporter.

Current practice among FAs is inconsistent, but weighs heavily in favor of including the citation in the lead sentence. Shostakovich v. Twentieth Century-Fox Film Corp. does not include the Bluebook citation, but United States v. Wong Kim Ark, United States v. Washington, United States v. Progressive, Inc., and Washington v. Texas do. In all cases that included the citations in the lead sentence, the abbreviations are not spelled out. Edge3 (talk) 20:05, 21 January 2024 (UTC)

• " observed members of the Champaign city council and the mayor using their personal electronic devices to send messages during a public meeting". Is the date knowmn?

  The date is not known. The only clue is that Wade requested records from meetings "since (and including) May 3", until the date of his request, July 15. Edge3 (talk) 16:28, 23 January 2024 (UTC)

• "An attorney for the city also advised". Advised whom?

  Wade. I've clarified. Edge3 (talk) 16:28, 23 January 2024 (UTC)

• There are a lot of quotations in this. Few of which seem necessary in the light of MOS:QUOTE. ("While quotations are an indispensable part of Wikipedia, try not to overuse them. Using too many quotes is incompatible with an encyclopedic writing style and may be copyright infringement, and so most of the content should be in the editor's own words. Consider paraphrasing quotations into plain and concise text when appropriate".) I suggest paraphrasing most, or all, of them as the MoS suggests. Or just removing the quote marks; eg in "The opinion referred to FOIA's definition of "public records", which includes ..." "public records" in particular is frequently within quotation marks; is there a reason?

  Most of those quotes (like "public records") were for specific legal terminology that I was trying to distinguish. But looking at it closer, I agree with you that the quotation marks are not necessary per MOS:QUOTE. Edge3 (talk) 16:28, 23 January 2024 (UTC)

• "the Appellate Court later that summer". MOS:SEASON?

  Appeals in Illinois must be filed within 30 days of the lower court's judgment. However, since the exact timing of the appeal is not important to the article, I've removed "that summer". Edge3 (talk) 16:28, 23 January 2024 (UTC)

• "The court found that members of a city council do not constitute a "public body" when acting individually. Rather, they act as a collective body, after convening a meeting with the other members of the city council". I am not sure that "Rather" achieves the meaning you wish. Perhaps 'However' or 'But'?

  Added "But" Edge3 (talk) 17:47, 23 January 2024 (UTC)

• "Illinois Policy praised the ruling as". Could we be told in line what Illinois Policy is?

  Added a brief explanation. Edge3 (talk) 17:47, 23 January 2024 (UTC)

• "the court recommended that the General Assembly expressly amend FOIA if it intended messages stored on personal devices to be subject to disclosure". Just checking that you got this right. I can't access the source, but it would seem work reasonable that 'the court recommended that the General Assembly expressly amend FOIA if it intended messages stored on personal devices not be subject to disclosure'.

  The Senat 2014 source states: In July 2013, the Illinois Court of Appeals called upon the general assembly to expressly amend the state open records law if it "intends for communications pertaining to city business to and from an individual city council member's personal electronic device to be subject to FOIA in every case." You can also see the quoted language in the appellate opinion itself on paragraph 44: If the General Assembly intends for communications pertaining to city business to and from an individual city council member’s personal electronic device to be subject to FOIA in every case, it should expressly so state. I still think the current article's phrasing is closer to the sources, but I'd welcome your thoughts. Edge3 (talk) 18:04, 23 January 2024 (UTC)

• "the court recommended that the General Assembly expressly amend FOIA". What's "the General Assembly"?

  Added a brief explanation. Edge3 (talk) 17:47, 23 January 2024 (UTC)

Nice. I enjoyed that. Gog the Mild (talk) 19:37, 22 January 2024 (UTC)

Image review - pass

• Any reason there is no alt text for the infobox image? Gog the Mild (talk) 19:40, 22 January 2024 (UTC)

  I noticed that a few days ago and added it in. Did I not do it correctly? Edge3 (talk) 20:18, 22 January 2024 (UTC)

Apologies. I was looking for "alt", I wasn't aware there was a parameter "imagealt".

• All images are appropriately licenced, positioned, captioned and alt texted. Gog the Mild (talk) 20:52, 22 January 2024 (UTC)

Comments from Elli

• Is there a particular reason that Wade thought the messages might be interesting? (Or was it just that they were being used during the meeting, without any idea of what they might contain?)

  I couldn't find any specific reason that Wade wanted those records. In my experience, FOIA disputes are more about forcing public officials to act in full transparency. It's not necessarily the case that there is something noteworthy or provocative within the records themselves. In fact, most public records received through FOIA requests are actually quite boring. However, I was able to find that 24 pages of emails (from the city-owned accounts, not the private accounts) were initially released, so I've added that in. Edge3 (talk) 06:13, 27 January 2024 (UTC)

• Is Quinn also a notable case?

  I did some digging, and I don't think so. I couldn't find any scholarly coverage from the 1990s, when that case was decided. Quinn is mentioned by more modern sources only for comparison to the City of Champaign case. Edge3 (talk) 06:13, 27 January 2024 (UTC)

• There isn't any coverage of what was actually in the messages, even though that was the basis of this case. Am curious if this ever got any coverage?

  I couldn't find any coverage of the contents of those messages. My guess is that they were so boring that there was nothing worth reporting. Makes you wonder why Champaign used so much public resources to fight the case. But like I said above, FOIA lawsuits are often about the principle of transparency vs. secrecy, rather than the contents of the records themselves. Edge3 (talk) 06:13, 27 January 2024 (UTC)

  Makes sense. Is kinda what I assumed but wasn't sure. Elli (talk | contribs) 06:30, 27 January 2024 (UTC)

Overall this is quite a good article and I enjoyed reading it. Elli (talk | contribs) 19:08, 25 January 2024 (UTC)

Thanks so much! I've also incorporated some info I just found regarding the University of Illinois controversy. Since you're such an expert on local/state politics, I figured you might enjoy the additional material. Edge3 (talk) 06:13, 27 January 2024 (UTC)

Ooh, nice. Comfortable with supporting now. Elli (talk | contribs) 06:30, 27 January 2024 (UTC)

Source review

Not sure that I like the way #8 is used; the paragraph begins with a reference to a court ruling but then cites a law; I would cite only the law to #8 and use a different sauce for the court ruling. Does #12 have a link? Regarding #14, our page on the think tank calls that think tank "conservative and libertarian" while this article says they are conservative; why the selectiveness? Otherwise, the format seems consistent and the sources OK. Jo-Jo Eumerus (talk) 17:06, 29 January 2024 (UTC)

• I've used the opinion itself as a citation, in addition to #8 to cite the statute.
• #12 can be found on the archive of the Illinois Bar Journal. (Specifically, click on page 504, "Illinois Law Update".) However, the article is hidden behind a paywall so I didn't use the link. Instead, I access the article via a university library.
• I checked the sources for Illinois Policy Institute, and I don't believe the sources support a label of "libertarian". ProPublica uses only the term "conservative", and so does the Chicago Tribune.

Thanks for your comments! Edge3 (talk) 19:34, 29 January 2024 (UTC)

Going to AGF on the Illinois Policy Institute thing, then. Going to throw my usual caveats about not being familiar with the topic and lack of spotcheck, though. Jo-Jo Eumerus (talk) 07:38, 30 January 2024 (UTC)

For what it's worth, I've edited the Illinois Policy Institute page to remove the "libertarian" label. Edge3 (talk) 19:36, 30 January 2024 (UTC)

Support from ZKang123

A rather interesting case. I will give this a look.

Early comments:

• "the part of the office of the Illinois Attorney General" – ""an attorney office of the Illinois Attorney General". Or reword so as to avoid "of the... of the..."

  Reworded to say "bureau of the Illinois Attorney General" Edge3 (talk) 06:35, 8 February 2024 (UTC)

• "that is responsible" - "that is" is redundant.

  Changed Edge3 (talk) 06:35, 8 February 2024 (UTC)

• "Binding opinions are rare; the Attorney General issues them in only less than 0.5 percent of complaints submitted to the Public Access Counselor. (Most complaints are resolved by non-binding advisory opinions.)" – for the bracketed portion, either make into a footnote or just remove them. Also, I think it would benefit by also explaining what a binding opinion is, or wikilink accordingly.

  I've converted that note to a footnote, and I've added a wikilink to legal opinion. Edge3 (talk) 05:46, 9 February 2024 (UTC)

• "but rather must be submitted to a public body." – "but must instead be submitted to a public body."

  Changed Edge3 (talk) 06:35, 8 February 2024 (UTC)

• "Here, the opinion concluded that it is consistent with the court's ruling in Quinn, by finding that the communications of city officials are not records of the officials themselves, but rather the city." – "In this case, the opinion affirmed the court's decision in Quinn, but asserted that the communications of city officials are considered records of the city and not of the officials individually."

  I like your proposed phrasing. Changed. Edge3 (talk) 06:35, 8 February 2024 (UTC)

• "With the option of filing in either the Circuit Court of Cook County or that of Sangamon County, the city had to make a strategic decision on where to appeal." – "The city had to make a strategic decision on where to appeal – either the Circuit Court of Cook County or that of Sangamon County"

  Changed. Thanks! Edge3 (talk) 06:35, 8 February 2024 (UTC)

• "ultimately appealed the Attorney General's opinion to the circuit court of Sangamon County." – was it said why? Also what would be the difference in where they would appeal?

  There was no reason given. Selecting the venue depends mainly on which county's circuit court tends to rule more favorably towards the plaintiff on this type of case, and whether the appellate case law tends to be more favorable in one jurisdiction versus another. The Illinois Appellate Court is divided into five districts, and each district would have varying precedents that apply to the cases heard within that district. Edge3 (talk) 05:46, 9 February 2024 (UTC)

• "upheld the opinion that the messages were public records, but on more limited grounds." – what limited grounds?
• Never mind, I saw these are further elaborated in the subsequent paragraph.
• "Justices Thomas R. Appleton and Lisa Holder White, the other members of the appellate panel for this matter, agreed to Pope's opinion." – "The other members of the appellate panel, justices Thomas R. Appleton and Lisa Holder White, agreed with Pope's opinion."

  Changed. Edge3 (talk) 06:35, 8 February 2024 (UTC)

More to come.--ZKang123 (talk) 02:54, 8 February 2024 (UTC)

@ZKang123 Thank you for your feedback! I've responded to your comments above. Edge3 (talk) 05:46, 9 February 2024 (UTC)

Continued:

• For the next two paragraphs beginning with "The court found that members of a city council...", "Additionally, the court noted...", I think they can be summarised in one paragraph like:
  • The count found that, while the individual members of a city council are not considered a public body, they collectively form one during council meetings. Through this interpretation, messages sent to a council member's personal device at home are not subject to FOIA, even if related to public business, but messages created during council meetings are subject to FOIA. Additionally, a quorum of individual members constitutes a public body capable of making binding decisions. A communication becomes a record of a public body if forwarded to enough members to establish a quorum, and it may also be subject to disclosure when sent to a government-owned account.

  I like the way you consolidated these paragraphs. Done. Edge3 (talk) 00:43, 11 February 2024 (UTC)

• "The court's decision was the first in Illinois to" – "This was the first court decision in Illinois to..."

  Changed. Edge3 (talk) 00:43, 11 February 2024 (UTC)

• "The city announced that it intended to comply with the court's ruling, noting that there were "very few documents" to release. It did not plan to appeal the case any further." – Combine the sentences: "The city announced that it intended to comply with the court's ruling, noting that there were "very few documents" to release, and did not plan to appeal the case any further."

  Done. Edge3 (talk) 00:43, 11 February 2024 (UTC)

• " that the General Assembly" – "that the Illinois General Assembly". Also remove the bracket portion; I think it's clear.

  I've specified Illinois General Assembly. I also removed the bracketed portion "(the state legislature)". I had initially added it because @Gog the Mild: above asked, "What's 'the General Assembly'?" But now I agree that "Illinois General Assembly" requires no clarification, and anyone who needs more info can click on the link. Edge3 (talk) 00:47, 11 February 2024 (UTC)

Thanks for the ping. Bear in mind MOS:NOFORCELINK: "Do use a link wherever appropriate, but as far as possible do not force a reader to use that link to understand the sentence. The text needs to make sense to readers who cannot follow links." Gog the Mild (talk) 20:50, 14 February 2024 (UTC)

@Gog the Mild NOFORCELINK doesn't require an inline explanation alongside every link, and there's disagreement on the extent to which inline explanations should be required. See Wikipedia talk:Manual of Style/Linking#A change to NOFORCELINK. In this article, there is no further elaboration of "Illinois Attorney General" or "Illinois Appellate Court", so it follows that "Illinois General Assembly" should be treated in the same way. It is assumed that the average reader would be somewhat familiar with the term, especially considering that "General Assembly" is used in the name of several U.S. state legislatures. Edge3 (talk) 01:48, 15 February 2024 (UTC)

• "John M. O'Driscoll, a local government attorney, advised public bodies throughout Illinois to review their practices and ordinances to avoid having to disclose communications intended to remain private."
  • Rewrite to: John M. O'Driscoll, a local government attorney, has recommended public bodies across Illinois to review their practices and ordinances to avoid having to disclose private communications.

  Changed. Edge3 (talk) 02:37, 11 February 2024 (UTC)

• "aldermen" – what's an aldermen?

  An alderman is a member of a city council, but I concede that not everyone uses this term, so I've changed the text to say "council member". Edge3 (talk) 02:37, 11 February 2024 (UTC)

  Truthfully you can keep the term if its the established norm or title in context, and wikilink accordingly. Otherwise, you are free to change.--ZKang123 (talk) 04:41, 11 February 2024 (UTC)

  No worries, I'll just leave it as "council member" since it's more widely understood. The word "alderman" is often used in Illinois government but it's not necessary. Edge3 (talk) 16:34, 11 February 2024 (UTC)

• " Regarding employees (rather than elected members) of the public body, the applicability of City of Champaign was unclear" – "The applicability of City of Champaign for employees of a public body remains unclear"

  Changed. Edge3 (talk) 02:37, 11 February 2024 (UTC)

• "In May 2016, the Circuit Court of Cook County clarified the matter when it ruled that personal emails of Chicago Mayor Rahm Emanuel may be subject to disclosure, even when stored on private devices.[18] The judge in that case cited the City of Champaign ruling." – In May 2016, the Circuit Court of Cook County cited the City of Champaign ruling when it ruled that personal emails of Chicago Mayor Rahm Emanuel may be subject to disclosure, even when stored on private devices.[18][19]"

  Done. Edge3 (talk) 02:37, 11 February 2024 (UTC)

I think that's all.--ZKang123 (talk) 08:22, 9 February 2024 (UTC)

@ZKang123 Thanks so much! I believe I've addressed the remaining comments, but please let me know if there's anything else. Edge3 (talk) 03:19, 11 February 2024 (UTC)

No other comments. Happy to support.--ZKang123 (talk) 04:23, 11 February 2024 (UTC)

• Closing note: This candidate has been promoted, but there may be a delay in bot processing of the close. Please see WP:FAC/ar, and leave the {{featured article candidates}} template in place on the talk page until the bot goes through. FrB.TG (talk) 18:01, 16 February 2024 (UTC)

The above discussion is preserved as an archive. Please do not modify it. No further edits should be made to this page.