In Chicago Tribune v. The College of DuPage and The College of DuPage Foundation, the Appellate Court of Illinois, Second District issued a unanimous decision ordering a public college’s fundraising organization to release records in its possession pursuant to a state Freedom of Information Act (“FOIA,” a.k.a. “sunshine law”) request. The Court in this case held that the College’s separately incorporated foundation conducts government business on its behalf and therefore is subject to the Illinois FOIA laws.