County Weighs Screening FOIA Requests for AI Bots Under New Law

Montgomery County Board Coordinating Committee Meeting | June 25, 2026

Article Summary: The Montgomery County Board Coordinating Committee on Thursday, June 25, 2026, discussed recommendations from the county’s human resources consultant on verifying suspicious Freedom of Information Act requests, and the committee’s handouts include a template letter from the State’s Attorney’s office that would pause the county’s response clock until a requester confirms they are a human being. No motion was made and no vote appears in the minutes.

FOIA Bot Verification Key Points:

• The committee discussed recommendations from Bushue HR on verifying suspicious FOIA requests; the minutes record no motion and no vote.
• A template letter in the handouts, signed by State’s Attorney Brian Shaw as FOIA officer, cites section 3(j) of the Illinois Freedom of Information Act, 5 ILCS 140/3(j), as authority to act when the office has “a reasonable belief” a request came from an automated system or artificial intelligence rather than a natural person.
• The letter would stay the county’s five-business-day response deadline until the requester verifies, orally or in writing, that they are a natural person — and would treat the request as abandoned and formally deny it if no verification arrives within 30 days.
• The letter states the county would not require personal identifying information, such as a photo ID, to complete the verification.

MONTGOMERY COUNTY — The Montgomery County Board Coordinating Committee on Thursday, June 25, 2026, took up the question of whether the public records requests arriving in county inboxes are being written by people.

Under the heading “FOIA Bot Verification,” the committee’s minutes record a single sentence: the committee discussed recommendations from Bushue HR on verifying suspicious FOIA requests. No motion was made, no vote was taken, and the minutes record nothing about what the recommendations were, who spoke to them, or what the committee thought of them.

The committee’s handouts, however, contain a document that shows what such a verification would look like in practice. It is a form letter addressed “Dear Requester,” signed by Brian Shaw as FOIA officer for the Montgomery County State’s Attorney, with a highlighted placeholder where the date of a request would be filled in.

What the Letter Would Do

The letter tells a requester that the county has received their Freedom of Information Act request by email, and that, pursuant to section 3(j) of the Illinois Freedom of Information Act, 5 ILCS 140/3(j), the office “has a reasonable belief that your request was not submitted by a natural person, but rather by an automated system or artificial intelligence.”

Four consequences follow, each spelled out in the letter under its own heading.

The first is timing. The county’s statutory five-business-day deadline to respond is “hereby stayed (paused)” until the requester verifies that they are a natural person. The second is the method: verification may be made in writing, or by calling the Montgomery County State’s Attorney’s Office at 217-532-9551. The third is a limit on what the county will ask for — under the heading “Privacy Protection,” the letter states that in accordance with Illinois law the office does not require personal identifying information, such as a photo ID, to complete the verification.

The fourth is the consequence of silence. If no verification is received within 30 days of the notice, the letter states, the request “will be considered abandoned and will be formally denied under the statute.” If the requester does verify, the letter says, the office will resume processing the request within the standard statutory timeframe.

What the Record Does Not Say

The minutes do not state that this letter is the Bushue HR recommendation the committee discussed, and the letter itself carries no reference to the consultant. It is signed on the State’s Attorney’s authority. Nothing in the record establishes whether the letter has been adopted, whether it is already in use, or whether any request has yet prompted the county to send one. The date field is blank.

Nor does the record indicate what makes a request suspicious in the county’s judgment — the volume, the phrasing, the sender, or something else. The letter describes a belief the office may form; it does not describe how.

The committee is the board’s coordinating body, and any action it takes is a recommendation that must go to the full County Board before it carries any force. In this instance the committee did not act at all. The item was titled “Update/Approval,” a formulation this county applies to items that receive no motion as often as to items that do.

Bushue HR, an Effingham firm, appears twice more on the same June 25 agenda: the county’s HELP Safety Committee reviewed a Return to Work Policy the firm recommended, and the Development & Personnel Committee’s anticipated business included an employee handbook update the firm was expected to recommend.

Five of the committee’s six members were present — Connie Beck, Ethan Murzynski, Chad Ruppert, Dr. Patty Whitworth and Chairman Doug Donaldson. Mark Hughes was absent. There were no public comments. The meeting adjourned at 9:54 a.m.