Scope of exemption of legal invoices
A public body received a FOIA request for its legal bills. It denied the request citing several exemptions under FOIA.
The PAC instructed the parties that records containing the following information must be disclosed:
a. general descriptions of the nature of the services performed by an attorney,
b. dates on which work was performed,
c. the initials of the attorney performing the work,
d. the numbers of hours billed, and
e. the corresponding dollar amount billed for each entry.
The PAC did inform the parties involved that any descriptive entries contained in legal invoice records that describe services rendered, which reveal privileged attorney-client communications may be redacted (withheld or blacked-out on a document that contains exempt and non-exempt records) under section 7(1)(m) of FOIA.
This opinion is binding only to the parties involved and may be appealed pursuant to State law.