Rockford Newspapers Inc. v. Northern Illinois Council on Alcoholism and Drug Dependency was a case before the Illinois Second District Appellate Court in 1978 concerning the applicability of open records laws to private corporations and non-profits.
This case relies on an outdated formulation of the Illinois Freedom of Information Act and would no longer be applicable with the new wording of the law introduced on January 1, 2010.
- Northern Illinois Council on Alcoholism and Drug Dependence (NICADD) is a private non-profit corporation that maintains a number of drug abuse treatment facilities in Winnebago and Boone counties.
- On September 15, 1976, a reporter from the Rockford Newspapers was denied access to a NICADD meeting.
- The Reporter quickly filed suit, seeking to compel the agency to hold public meetings under the Illinois Open Meetings Act.
- The trial court ruled in favor of NICADD.
- The reporter appealed the decision arguing that NICADD was a subsidiary body because 90% of its funding came from public funds and because it was regulated and controlled by government agencies.
Ruling of the court
The Trial court ruled in favor of NICADD, determining that it was not subject to the Illinois Open Meetings Act.
The Court of Appeals affirmed the decision of the trial court. The court rejected the newspapers claim that funding alone rendered an agency a public body. The court felt that despite the funding the private legal nature and the independence of the board of directors removed NICADD from the sphere of private bodies subject to public records requests. It is for this reason specifically that the court of appeals affirmed the trial courts decision and determined that the meetings laws did not apply to the organization.