The State Can Track the Deadline Just Not Who Made the Decision
The State Can Track the Deadline Just Not Who Made the Decision
IDFPR produced thirteen spreadsheets, nine requests, two FOIA officers and one email to General Counsel. The decision chain remained blank.
F’nAround Media
October 3, 2026
I asked the Illinois Department of Financial and Professional Regulation a simple process question: Who handled my Freedom of Information Act requests?
Not who was accused of misconduct. Not what an attorney privately advised. Not the substance of a confidential investigation.
Who received the requests? Who prepared the responses? Who reviewed them? Who approved the extensions, denials and productions? What routing or tracking record shows how each request moved through the agency?
IDFPR’s October 2 response said that, after a reasonable search, it found no responsive non-confidential records for most of those categories. The agency said its FOIA logs did not contain the requested information and invoked attorney-client, work-product and deliberative-process exemptions for other portions of the request.
Then IDFPR attached thirteen spreadsheets and an email exchange.
Those attachments did not answer the central question. But they revealed a great deal about the process surrounding it.
The request
The September 17 FOIA request covered my submissions from April 23 through September 17, 2026. It sought existing records sufficient to identify:
• the assigned FOIA officer for each request;
• anyone who prepared, reviewed, approved or authorized a response;
• the person who transmitted each response;
• routing, assignment, status, audit or workflow information; and
• the people designated as IDFPR FOIA officers during that period.
The request did not ask IDFPR to write a new narrative or answer interrogatories. It asked for the administrative trail already created while public business was conducted.
That distinction matters. FOIA generally does not require an agency to create a new record, but the entire purpose of requesting routing histories, assignment records, logs and metadata is to obtain records that already exist.
IDFPR’s answer was that no responsive non-confidential records were located for the first four categories. For the fifth, the agency produced a brief internal email exchange.
Two names in two minutes
At 5:01 p.m. on October 2, Acting FOIA Officer and Associate General Counsel Janel Haretoun emailed IDFPR General Counsel Louis A. Klapp. She asked whether Kavonnah Coleman had served as FOIA officer from April 23 through August 25, 2026, and whether Haretoun had served as acting FOIA officer beginning August 26.
At 5:03 p.m., Klapp answered: “Yes, those dates are correct.”
That exchange answered one part of the request. It identified two FOIA officers and their respective periods of responsibility. It also established that the Office of General Counsel possessed—or could promptly confirm—at least some personnel information relevant to the agency’s FOIA process.
The email does not establish that Klapp reviewed or approved the entire FOIA determination. The record supports only the narrower conclusion: Haretoun consulted him about the identity and dates of the FOIA officers, and he confirmed them.
That is still more process information than appeared in the spreadsheets.
Thirteen spreadsheets, nine requests and no decision chain
IDFPR produced thirteen weekly FOIA logs. Because the weekly files overlap, they document nine distinct requests from me during the relevant period.
The spreadsheets track familiar administrative facts: the requester, the date received, the statutory due date, any extension date and a description of the request. They also contain columns labeled “Division,” “Status” and “Additional Comments.”
For the produced entries, those process fields are blank.
The logs do not identify an assigned employee, reviewing attorney, approving supervisor, transmitting official or internal unit. They do not show a meaningful routing history. They do not show whether a request was sent to licensing, enforcement, cannabis regulation, investigations or legal. They do not identify who decided that records did not exist, that a request was burdensome or that an exemption applied.
In other words, the state’s logs can show when a request arrived and when the response clock ran. The versions produced do not show who made the decisions that followed.
That is not proof that no internal trail exists. It means the records produced do not contain one.
The spreadsheet knows the public better than the process
There is an uncomfortable imbalance in the logs.
They preserve requesters’ names, organizations, contact information, filing dates and detailed descriptions of what members of the public asked the state to disclose. Yet the fields that could document internal responsibility are largely empty.
The produced logs preserve a detailed record of the citizen asking the question without showing a comparable record of the official deciding the answer
That is the opposite of what an accountability system should make easy to see.
An effective tracking system should be able to answer basic operational questions:
• Which division received the assignment?
• Who conducted the search?
• Which records custodians were contacted?
• Who selected the exemptions?
• Who approved the final response?
• When was each step completed?
Those are not requests for private legal strategy. They are ordinary questions about how a public agency performed a public duty.
A five-year date error
The production also contains a data-quality problem.
An April 30, 2026 request concerning Icon Construction appears in three overlapping logs with a received date of April 30, 2021. The surrounding due and extension dates are in May 2026, making the error apparent from the face of the records.
A single incorrect date does not prove misconduct. It does demonstrate why audit trails and accountable review matter.
When an agency later relies on its tracking system to establish when a request arrived, whether a deadline was met or which version was reviewed, a five-year error is not cosmetic. It can distort searches, reporting and any later attempt to reconstruct what happened.
The response’s internal tension
IDFPR’s letter combines three positions:
1. no responsive non-confidential records were found for key portions of the request;
2. certain responsive categories would be protected by attorney-client, work-product or deliberative-process exemptions; and
3. related logs and an email were produced.
These positions are not necessarily legally incompatible. An agency can locate some related records, determine others do not exist and withhold still others under exemptions.
But a transparent response should make the categories clear. What was searched? What existed? What did not exist? What was withheld? Which exemption applied to which record? What factual and administrative information could be separated from privileged legal advice?
The October 2 letter does not provide that level of clarity.
It also contains an apparent citation problem. Its redaction discussion attributes preliminary drafts, notes, recommendations and deliberative material to Section 7(1)(a), (b) and (c). The deliberative-process exemption is ordinarily associated with Section 7(1)(f). That may be a drafting or template error, but statutory precision matters when exemptions are the reason public records are withheld.
Metadata is evidence of handling not proof of original responsibility
The spreadsheet file properties identify Haretoun as the creator and last modifier of the produced workbooks. The files were modified in sequence on October 2, shortly before the agency’s response.
That supports a limited conclusion: she appears to have prepared or modified the copies produced in response to this FOIA request.
It does not prove that she handled every underlying request when it was originally submitted. File metadata must be read carefully. A person assembling a production can become the recorded author of a copied workbook without having created its original entries.
Still, the metadata is exactly the type of administrative evidence the request sought: a record showing that a particular official touched a particular file at a particular stage.
The process can leave a trail. The question is whether IDFPR consistently preserves and produces it.
Why this matters beyond one requester
This is not merely a dispute over names.
FOIA is one of the few tools the public has to reconstruct government decision-making without litigation discovery. When a response is delayed, narrowed, denied, contradicted or changed, an assignment history can show whether the problem was clerical, technical, legal or supervisory.
Without that history, institutional responsibility dissolves into a shared mailbox.
The absence of a visible decision chain also creates risk for public employees. A complete workflow record can protect an employee who followed instructions, conducted an adequate search or raised a concern. A blank log leaves everyone and no one responsible.
That is how process failures become systemic. Each individual response can be described as an isolated mistake while the cumulative pattern remains hidden inside unrecorded handoffs.
My research refers to that dynamic as structural gravity: once a system repeatedly routes pressure away from accountability, every later action tends to follow the same path. The outcome does not require a single mastermind. It requires a process in which responsibility is difficult to identify and easy to diffuse.
What remains unanswered
After thirteen spreadsheets, an internal email and a formal response from an associate general counsel, several basic questions remain:
• Who handled each of the nine requests?
• Which divisions searched for responsive records?
• Who reviewed and approved each extension, denial or production?
• Who decided which exemptions applied?
• Are assignment and routing histories maintained somewhere outside the weekly logs?
• If those records exist, why were their nonexempt factual portions not produced?
• If they do not exist, how does IDFPR audit the quality and consistency of its FOIA work?
The response advises that the determination may be submitted to the Illinois Attorney General’s Public Access Counselor for review. That process exists precisely because a requester and a public body may disagree over the adequacy of a search, the application of exemptions or the segregation of nonexempt material.
The process is now the story
The original inquiries involved licensing, regulatory enforcement, referrals and decisions affecting a state-regulated industry. The latest records raise a separate institutional question: Can IDFPR reconstruct its own decision chain when asked?
Based on what it produced, the agency can identify the requester, copy the request text, calculate the deadline, record an extension and confirm who held the title of FOIA officer.
What it did not produce was the chain connecting the public’s question to the government’s answer.
That missing middle is where accountability lives.
IDFPR could tell me when the requests arrived, when they were due and when time was extended. It still could not or would not tell me who decided what happened next.
And now the process itself is a public record.
Source record
This article is based on the following records produced by IDFPR:
• J. Phelan Response Letter, dated October 2, 2026.
• FOIA Officer Email, October 2, 2026, identifying Kavonnah Coleman and Janel Haretoun and confirming their service dates.
• Thirteen IDFPR weekly FOIA log workbooks covering April 20 through September 18, 2026.
Illinois Freedom of Information Act: 5 ILCS 140
Illinois Attorney General, Public Access Counselor: PAC information and review process
Editorial note: This article reports what the produced records show and do not show. It does not establish criminal conduct or a final legal violation. Legal determinations concerning the adequacy of the response or application of exemptions belong to the appropriate reviewing authority or court.
