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IMPACT: Panel nixes FOIA bid against FBI

Published in the Chicago Daily Law Bulletin on July 22, 2025

By GRACE BARBIC

gbarbic@lawbulletinmedia.com

A former attorney attempting to prove he was a confidential informant for the FBI lost a bid to obtain hundreds of pages of 20-year-old documents from the federal agency under the Freedom of Information Act.

Joel A. Brodsky is a former lawyer well known for his representation of Drew Peterson, a former Bolingbrook police sergeant convicted of murdering his third wife, Kathleen Savio.

Brodsky argued on appeal that the district court erred in rejecting his effort to obtain documents withheld or redacted by the FBI under FOIA exemptions.

In a per curiam nonprecedential order, a panel of the 7th U.S. Circuit Court of Appeals affirmed the judgment of U.S. District Judge Sharon J. Coleman of the Northern District of Illinois, granting summary judgment in favor of the FBI.

The panel found that Brodsky did not establish clear error in the district court's application of the various FOIA exemptions.

The panel members included Circuit Judges Thomas L. Kirsch II, John Z. Lee and Doris L. Pryor.

Brodsky submitted a FOIA request to the FBI in October 2020, seeking all records concerning his work as a confidential informant from Jan. 1, 2000 to Oct. 11, 2020.

He stated that he was an informant for two investigations - one into corruption in the Domestic Relations Division of the Circuit Court of Cook County and the second into the murder of a member of an organized crime outfit in Chicago.

In emails to the FBI, he stated that he needed confirmation that he was a confidential informant for two unrelated cases.

The FBI eventually identified a total of 564 pages of responsive records. They released 14 pages in full, 84 pages in part and withheld 466 pages in full, documents stated.

Brodsky then sued the FBI for wrongfully withholding the records, and the FBI moved for summary judgment.

It explained that it withheld or redacted the documents Brodsky sought because one or more FOIA exemptions applied.

Those exemptions included section 522(b)(6), (b)(7)(C) regarding information that could be used to deduce facts that would invade privacy interests, section 522(b)(7)(A) regarding interference with enforcement proceedings, section 522(b)(7)(D) on identifying confidential sources and section 522(b)(7)(E) on risk of circumvention of the law.

The FBI claimed it could not segregate or disclose the documents without risking foreseeable harm, documents stated.

The FBI gave Brodsky a redacted Vaughn index, pursuant to Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973), describing the withheld documents cross-referenced with the relevant exemptions.

The FBI also filed a Glomar response, declining to confirm or deny the existence of some responsive records because the acknowledgment of their existence or non-existence could jeopardize the interests the FOIA exemptions are intended to protect.

The term "Glomar" derives from the D.C. Circuit's decision in Phillippi v. CIA, 546 F.2d 1009, 1011 (D.C. Cir. 1976), where the court upheld the CIA's refusal to confirm or deny its ties to Howard Hughes' submarine retrieval ship, the Glomar Explorer, documents stated.

Brodsky claimed that the court erred when it allowed him to view only a redacted version of the Vaughn index because the FBI "merely speculated" that he would be able to deduce the identities of people named in the documents.

But the panel disagreed.

"The FBI may submit a redacted Vaughn index when it fears that inferences from the Vaughn index could reveal classified sources or methods of obtaining intelligence," the panel wrote, citing Bassiouni v. CIA, 392 F.3d 244, 246?47 (7th Cir. 2004).

The panel found the court did not clearly err when it determined that revealing the existence of certain documents could jeopardize classified sources and intelligence methods.

Brodsky also argued that the court should not have allowed the FBI to submit a Glomar response because it is only appropriate in cases involving national security.

The panel noted that Brodsky cited no authority for this proposition.

He "merely asserted that there has never been a nonnational security case where a Glomar response was submitted," the panel wrote.

Documents stated that Brodsky suspects that there are people attempting to injure him in retaliation for his cooperation with the FBI.

He argued the public has an interest "in knowing if the FBI disclosed the identity of a cooperating witness to persons who then maliciously injured that witness."

The panel noted that in order for Brodsky to prevail on this claim, he must point to evidence that would "warrant a belief by a reasonable person that the alleged Government impropriety might have occurred," citing Nat'l Archives and Records Admin. v. Favish, 541 U.S. 157, 174 (2004).

"But his 'bare suspicion' that he is being targeted because of the FBI's impropriety is insufficient to establish that the district court clearly erred in its assessment of the FBI's withholdings," the panel wrote.

Brodsky made several other arguments, but the panel found they did not merit discussion.

Brodsky is self-represented.

"The refusal to give me documents about myself regarding events from 20+ years ago happened under the Biden administration and former FBI Director [Christopher] Wray. It was their objections the Court relied on," Brodsky said in a written statement. "I hope that the FBI is more transparent under President [Donald] Trump and Director [Kash] Patel, as they promised they would be, as I am strongly considering making a new FOIA request asking that they reconsider the previous objections."

The FBI is represented by Jonathan C. Haile of the Office of the U.S. Attorney for the Northern District of Illinois. He could not be reached for comment.

The case is Brodsky v. FBI, No. 24-2619.

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FOR IMMEDIATE RELEASE: Aug. 26, 2026

Media Contact Information:
Cartwheel
Emily Paisner
(888) 500-2067
emily.paisner@cartwheelcare.org
 

Cartwheel Care expands
telehealthmental health services
to 100,000 K-12 students across Illinois

 

$1 million grant from Blue Cross and Blue Shield of Illinois will help Cartwheel scale access to care in rural and underserved communities through 2028


CHICAGO — August 26, 2026 — Cartwheel Care, a telehealth mental health provider for K-12 schools, today announced plans to expand access to care for up to 100,000 students across Illinois, supported by a $1 million grant from Blue Cross and Blue Shield of Illinois (BCBSIL). The additional funding builds on an existing partnership between Cartwheel and BCBSIL, following a year of strong engagement and clinical outcomes. Cartwheel currently serves 40 Illinois school districts, and the grant will help expand services further into rural and underserved communities across the state through 2028.

Mental health needs among Illinois students remain high. According to data from Lurie Children’s Hospital, approximately 50% of Illinois youth (ages 2–17) have experienced worsening mental health symptoms in recent years. At the same time, access to care has not kept pace: more than 80 of Illinois’ 102 counties have no practicing child psychiatrist, and the shortage is most acute in rural areas, where families often wait months for an appointment or travel significant distances for care.  

Cartwheel’s telehealth model is designed to remove the access barriers rural families face, like long waitlists and the need to travel to see a provider. By partnering with schools, Cartwheel provides licensed, Illinois-based clinicians with no waitlist, accepts all major insurance plans including Medicaid, and reaches kids and families where they already are, without requiring them to find or travel to an outside provider.

“Every student experiences mental health challenges differently, and there’s no one-size-fits-all approach to supporting them,” said Dr. Juliana Chen, chief medical officer at Cartwheel. “Our goal is to meet students and families where they are, with practical support that helps them build skills, strengthen relationships, and feel more confident navigating challenges at school and at home. BCBSIL’s support is what allows us to bring that care to more Illinois communities.”

“Supporting the health and well-being of Illinois youth is critical to building stronger communities,” said Brian Snell, president of Blue Cross and Blue Shield of Illinois. “The results we’ve seen through our partnership with Cartwheel demonstrate the impact that timely, accessible mental health services can have for students and families. This investment will help bring those services to even more communities across our state.”

To date, four Illinois districts have received Cartwheel’s services through this grant: Steger SD 194 in Cook County and Will County, Troy CCSD 30-C in Will County, Mattoon CUSD 2 in Coles County, and Wolf Branch SD #113 in St. Clair County.  

In the first year of the program, more than 200 students were referred for care and completed more than 1,000 telehealth sessions. Appointments were scheduled in the same week with no waitlist. Sixty-eight percent of students served were covered by Medicaid or uninsured. Overall, 73% of students showed meaningful improvement in anxiety and depression symptoms on standard clinical screeners (GAD-7/PHQ-9).

Additional districts where Cartwheel services are launching this fall include Litchfield CUSD #12, Panhandle CUSD #2, Leyden High School District #212, and Regional Office of Education #40. With the support of this grant, Cartwheel expects to expand into another 30 to 50 school districts, bringing access to care to a total of 100,000 students across Illinois.

“Before this partnership, getting a student connected to care could take months,” said Jeffrey Peterson, director of student services & records at Troy CCSD 30-C. “Now our counselors can refer a student, know they’ll be seen within days, and are seeing real improvements as a result.”

Through the grant, Cartwheel provides individual and family therapy, parent guidance, psychiatric evaluation and medication management, and specialized care programs for challenges like school avoidance, social media use, and intense emotions and behavior challenges.

As reported in Illinois Policy, in 2025 about 25% of Illinois students missed at least 10% of the school year and this was more severe among low-income students, with 35.1% in that group chronically absent. Cartwheel’s school avoidance program delivers evidence-based care designed specifically for students struggling with school avoidance. In partnership with Cartwheel, Peoria Public Schools saw a 62% reduction in absences per student, along with decreases in suspensions and symptoms of depression and anxiety.

Illinois school districts that want to learn more about this opportunity for the upcoming school year should visit: www.cartwheel.org/illinois.

About Cartwheel
Cartwheel is the nation’s largest and most trusted telehealth provider for K-12 schools, students, and families. Cartwheel partners with 350 school districts across 15 states to deliver comprehensive mental health services to students, families, and school staff. Founded in 2022 by educators and clinicians, Cartwheel combines evidence-based clinical care with technology to ensure every child has access to high-quality mental health support. Cartwheel accepts all major insurance plans including Medicaid and provides care at no cost to uninsured families. For more information visit: www.cartwheel.org.

About Blue Cross and Blue Shield of Illinois
Blue Cross and Blue Shield of Illinois is the largest health insurer in Illinois, serving nine million members and operating in all 102 Illinois counties. BCBSIL is a division of Health Care Service Corporation, a Mutual Legal Reserve Company and an Independent Licensee of the Blue Cross and Blue Shield Association. Learn more at bcbsil.com and follow us on Facebook and LinkedIn.  

 

 
 
 

 

 

 
 

FOR IMMEDIATE RELEASE: Aug. 24, 2026

Media Contact Information:
Mather Institute
Cindy Droog, president, Sabo PR
(616) 717-8654
cindy@sabo-pr.com
 

First-of-its-kind map shows opportunities
to improve social wellness for older adults
in Chicago


Free online tool by Mather Institute supports local planning, partnership and investments
 

EVANSTON, Illinois – Chicago has a new tool to help understand where neighborhood conditions support social wellness among older adults – and where thoughtful investment and partnership may expand opportunities. 

Mather Institute launched a first-of-its-kind free Social Wellness Map, which scores the 77 community areas in Chicago on social wellness – a measure of feeling connected with others and with a community – for adults 55 and better. Previous research shows strong social ties are one of the most important predictors of a happy and long life, and that neighborhoods and communities shape how people interact, support one another and build shared identity. Mather Institute developed the map in partnership with NORC at the University of Chicago. 

Designed as a planning and advocacy resource, the interactive map can help policymakers, community organizations, funders, planners and service providers explore local patterns, identify assets and consider where new investments may have the greatest benefit for older adults.

“Social wellness is a crucial, yet often overlooked, part of healthy aging,” said Cate O’Brien, MPH, Ph.D., chief transformation officer at Mather Institute. “Because every community contains diverse histories, people and experiences, the map is intended to inform – not replace – local knowledge. The most useful next step is conversation. When organizations bring this data together with resident voices, they can better understand what is already working and what could be most beneficial to older adults and their communities.”

The map is based on a new survey of more than 4,000 Chicago residents age 55 and better, combined with public data on community conditions, including walkability, economic factors and access to gathering places such as libraries, churches and community centers. Factors such as crime, lack of local businesses and poverty can hinder social wellness, but don’t tell the whole story. 

Users can view a side-by-side comparison of communities to explore how social wellness relates to health, happiness, income and other factors.

Key findings include:

  • Social wellness doesn’t follow traditional geographic divides: Community areas with stronger and weaker social wellness are found throughout Chicago, suggesting income and crime do not tell the whole story of connection.
  • Community conditions are connected to social wellness: Social wellness tends to be stronger in areas with greater walkability, convenient access to services, a stronger sense of safety and stronger social cohesion.
  • Social wellness aligns with broader well-being: Community areas with stronger social wellness also tend to report better health and happiness, a greater sense of meaning in life and fewer feelings of depression, anxiety and stress.
  • More gathering places do not automatically mean more connection: This suggests that access to preferred gathering places might matter more than the number of nearby options.
  • Stability and trust are important: Social wellness tends to be stronger where residents have lived longer, more residents own their homes and neighbors trust and support one another.

“Community leaders often have deep local knowledge, but need data to support the case for programs, funding and partnerships,” said Jennifer L. Smith, Ph.D., vice president of Mather Institute. “The Social Wellness Map offers another lens for understanding older adults’ experiences and for turning local insight into action.”

High social wellness scores were not confined to one part of Chicago or to its wealthiest areas, suggesting that other factors such as neighborhood identity, belonging and longstanding social ties are also important to connection.

Chatham emerged as a notable example, with a social wellness score of 8.14 out of 10, illustrating social wellness reflects aspects of community life beyond economic and safety indicators alone. Beverly received the highest community connectability score: 100 out of 100. Beverly is notable for its low crime rates, a strong family culture and several longstanding community gathering places. Jefferson Park stood out for having community conditions that support connection such as accessible transit, retail activity and established cultural gathering places.

The map is free to use and does not require user registration. It can be explored at: https://www.matherinstitute.com/social-wellness-map/ 

 

About Mather and Mather Institute

 

Based in Evanston, Illinois, Mather is a not-for-profit organization founded in 1941 that is dedicated to a vision of changing the way society views aging. Mather creates Ways to Age Wellâ„  through programs, places and residences for today’s older adults. These include developing and operating communities that support older adults in pursuing wellness and fulfillment; sparking creativity and connections for older adults in Chicagoland and beyond; and through Mather Institute, conducting research and incubating innovation to help all live and age well. 


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