Gekas v. Williamson , (4th Dist. July 20, 2009)

Internal investigation documents

In this case, plaintiff alleged police brutality on a routine traffic stop. During the proceedings he requested internal investigation documents from the police. The police declined on the grounds the requested documents were part of a personnel file and exempt from FOIA (Freedom of Information Act). At trial, the Court of Appeals concluded that only "personal information" in police personnel files are completely exempt from disclosure, merely placing documents within personnel files does not automatically confer exemption.