Local Government Law Bulletin

Tuesday, August 15th, 2017

New Laws Seek to Consolidate Units of Local Government

Governor Rauner signed into law amendments to various existing laws that are intended to expand the consolidation of various units of local government. Part of the legislation expands the Local Government Reduction and Efficiency Division of the Counties Code to apply to all counties (it currently applies only to DuPage, Lake, and McHenry Counties). The amendments also better clarify how obligations of a dissolving unit of local government are administered and assumed by the absorbing unit of government.

An amendment to the Township Code removes the limit of townships to 126 square miles, thus making it possible for several townships to consolidate into one. Other amendments allow for more flexibility in township consolidation into other townships or into a municipality.

The scheduled effective date of the amendments is Jan. 1, 2018, although the effect of the amendments is conditioned on the passage of other pending bills.

Brad Stewart

Author: Brad Stewart

Monday, August 14th, 2017

New Law Creates Additional FOIA Exemptions

Earlier this month, Governor Rauner approved a bill creating additional exemptions under Illinois’s Freedom of Information Act. Public Act 100-0026 creates three new exemptions which allow public bodies to deny FOIA requests sent by incarcerated persons. Specifically, the bill amends Section 7 of the FOIA to include the following:

“ . . . [T]he following shall be exempt from inspection and copying:”

* * *

(e-8) Records requested by a person committed to the Department of Corrections or a county jail, the disclosure of which would result in the risk of harm to any person or the risk of an escape from a jail or correctional institution or facility.

(e-9) Records requested by a person in a county jail or committed to the Department of Corrections containing personal information pertaining to the person’s victim or the victim’s family, including, but not limited to, a victim’s home address, home telephone number, work or school address, work telephone number, social security number, or any other identifying information, except as may be relevant to a requester’s current or potential case or claim.

(e-10) Law enforcement records of other persons requested by a person committed to the Department of Corrections or a county jail, including, but not limited to, arrest and booking records, mug shots, and crime scene photographs, except as these records may be relevant to the requester’s current or potential case or claim.”


In sum, public bodies are exempt from disclosing the following records to incarcerated people:

  • Records that would risk harm or escape from a correctional facility
  • Records concerning the incarcerated person’s victim
  • The arrest records of other people.

As such, municipalities should keep this new law in mind whenever responding to FOIA requests from incarcerated persons.


Author: Jacob D. Caudill

Monday, July 24th, 2017

Illinois Attorney General Issues Two Binding Decisions Concerning FOIA

This month, the Attorney General’s Office released two binding Public Access Opinions concerning Illinois’s Freedom of Information Act. Specifically, both opinions (the eighth and ninth of 2017) concern a public body’s duty to respond to FOIA requests. Notably, one of the public bodies involved  is the Office of Governor Bruce Rauner.

In both opinions, FOIA requests were sent  seeking a variety of records. The request sent to the Governor’s office sought “emails that Deputy Governor Leslie Munger sent or received since she became Deputy Governor; and Munger’s daily schedule for the next six months.” The public bodies in both matters never released the requested records and failed to respond to the inquiries of the Public Access Counselor as to the status of the FOIA request.

As such, the Attorney General’s Office determined that both public bodies violated Section 3(d) of the FOIA, which requires that “[e]ach public body shall, promptly, either comply with or deny a request for public records within 5 business days after its receipt of the request, unless the time of the response is properly extended.”

While these opinions do not provide any new guidance, they do show that the Attorney General’s Office will not hesitate to issue a binding opinion against those that ignore Illinois’s FOIA, even the Governor’s Office.


Author: Jacob D. Caudill

Monday, July 24th, 2017

Case Upholds Ordinance Prohibiting Unregistered Vehicles on Private Property

In mid-July, the Second Appellate Court upheld the Village of Round Lake Beach’s ordinance which provides: “It shall be unlawful to store any vehicle upon open private land unless such vehicle shall be duly registered for operation on public highways in the state…” Significantly, the Court made its decision on the limited issue of home rule authority which the Village possessed; it did not directly address if a non home rule unit would have the same valid police power.

However, a portion of the decision which addressed the reasonable relationship of the ordinance to a public interest could be cited as strong support for non home rule units to do the same: “It is reasonable to attack the problems associated with unused vehicles by prohibiting the unenclosed storage of vehicle that cannot be driven legally. Thus, the ordinance is a valid exercise of the Village’s police power.”

Our opinion is that this decision is strong support for municipalities to regulate vehicles on private property, but not an unlimited recognition of power. A municipality which already has or would like to implement an ordinance pertaining to inoperable and/or unregistered vehicles in open view on private property, is directed to review the public interest being served (i.e., reduction in vermin infestation, the aesthetics of the community, reduce risk of vandalism) and clearly articulate those interests in adopting or revising a similar ordinance.

Brad Stewart

Author: Brad Stewart

Thursday, June 22nd, 2017

Appellate Court Rules No Issue of Material Fact Regarding Municipality’s Immunity from Liability

Recently, the 4th District Appellate Court, in Monson v. City of Danville, 2017 Il App (4th) 160593, upheld a trial court’s granting of summary judgment, finding that no issue of material fact existed, regarding whether a local government employee was immune from liability against negligence and willful and wanton conduct claims filed by a pedestrian who tripped and fell on a concrete sidewalk. The Court held that under the Local Governmental and Governmental Employees Tort Immunity Act, 745 ILCS 10/2-109 and 2-201, the government employee, and therefore the municipality, was immune from liability because the employee engaged in a discretionary act, executing policy regarding improving sidewalk conditions and enhancing the downtown area, when he decided not to repair the portion of the sidewalk on which the pedestrian tripped and fell. Discretionary acts “are those which are unique to the particular public office and involve the exercise of judgment.” Ministerial acts “are those . . . performed in a prescribed manner, in obedience to the mandate of legal authority, without regard to the exercise of discretion as to the propriety of the acts being done.”  Citing Kennel v. Clayton Township, 239 Ill. App. 3d 634 (4th Dist. 1992).

The Court further stated that whether the municipality had notice of the deviation was not the relevant issue, and noted that even if the government official had inspected the defect and decided to do nothing, he would still be immune from liability because he would have engaged in a discretionary function (even if the official’s determination could later be determined to be negligent). This ruling is consistent with a 2nd District case, Richter v. College of DuPage, where that court found that no issue of material fact existed where a government employee, and thus the municipality, was immune from liability because the employee’s actions in determining which sidewalk repairs to make were discretionary functions and policy determinations, and not ministerial functions.  Richter v. College of DuPage, 2013 IL App (2d) 130095.

Kristin G. Good

Author: Kristin G. Good

Thursday, June 22nd, 2017

Illinois Attorney General Issues Three More Public Access Opinions

This month, the Illinois Attorney General issued three binding Public Access Opinions concerning both Illinois’s Freedom of Information Act (FOIA) and the Open Meetings Act (OMA).

Public Access Opinion 17-004

In issuing its fourth binding Public Access Opinion of 2017, the Illinois Attorney General’s Office found that a municipality improperly went into closed session based upon Section 2(c)(11) of Illinois’s OMA. Under Section 2(c)(11) of the OMA, a public body may enter into closed session to discuss “[l]itigation, when an action against, affecting or on behalf of the particular public body has been filed and is pending before a court or administrative tribunal, or when the public body finds that an action is probable or imminent in which case the basis for the finding shall be recorded and entered into the minutes of the closed meeting.”

At issue was a municipality’s decision to enter closed session on the basis of “pending or probable” litigation to discuss the municipality’s continued participation in an intergovernmental agreement with an adjacent town. However, no case was currently pending, and the mayor had even stated that he “doubts there will be a lawsuit.” Additionally, no decision on whether the agreement would be altered or terminated had been made at the time the public body entered closed session. For these reasons, the Attorney General determined that the municipality’s closed session was not authorized by Section 2(c)(11) of the OMA.

While this binding opinion does not necessarily provide anything new, it does show that the “probable or imminent” litigation exemption will be enforced stringently.

Public Access Opinion 17-005

In the fifth binding Public Access Opinion of 2017, the Attorney General found that a municipality violated the FOIA by failing to disclose statistical data upon receiving a request for traffic counts from roadway monitoring operations.

The municipality claimed that this data was exempt under Section 7(1)(f) of the FOIA. Section 7(1)(f) exempts “[p]reliminary drafts, notes, recommendations, memoranda and other records in which opinions are formulated . . . .” The municipality argued that the statistical data should be exempt from disclosure because it is in preliminary draft form. However, after reviewing the responsive records, the Attorney General determined that “[t]he statistical information is purely factual, including numbers representing the traffic volume for [specific sections of roadways].” As such, the Attorney General found that the requested records were not exempt from disclosure. In so finding, the court reiterated that “simply because the data may be subject to review and possible revision does not make the data itself preliminary or deliberative communications within the scope of Section 7(1)(f).”

Public Access Opinion 15-006

In the sixth binding Public Access Opinion of 2017, the Illinois Attorney General’s office found that the Illinois Department of Corrections (IDOC) violated the FOIA. Specifically, a reporter with the Associated Press sent a FOIA request to the IDOC seeking records “sufficient to show the job titles, locations, and numbers of employees in each category which the Department of Corrections considers essential and who would be required to report to work in the event of interruption in state employee pay and the closing of some offices and services.”

In denying the request, the IDOC simply stated “to the extent [documents] exist, [the documents] are exempt from production pursuant to Section 7(1)(m)” and/or “Section 7(1)(f) [of FOIA].” On review, the Public Access Counselor sought a copy of the records in question for a confidential assessment, however, the IDOC refused to release the records to the Public Access Counselor.

As such, the Attorney General determined that the IDOC was in violation of Section 9(a) of the FOIA for failing to provide a “factual basis supporting either of its claimed exemptions.” Additionally, the IDOC was also found to be in violation of Section 9(c) for failing to provide copies of the records for confidential review. Interestingly, the Attorney General also took issue with how the IDOC worded its denial, specifically with the language stating “to the extent the records exist . . . .” Pursuant to Section 3(d) of the FOIA “[e]ach public body shall, promptly comply with or deny a request for public records within 5 business days after its receipt of the request, unless time for response is properly extended under subsection (e) of this Section.” The Attorney General went on to state that “[t]he options available under FOIA do not include responding in the hypothetical, by claiming that any responsive documents that may exist are exempt without acknowledging the existence of responsive records.

Although the Public Access Counselor was unable to review the records at issue, the Attorney General held that the asserted exemptions did not apply. Specifically, the exemption relating to attorney-client privilege and attorney work product (Section 7(1)(m)) did not apply because the IDOC did not provide “any factual basis, supporting legal authority, or objective indicia demonstrating that any responsive records are in fact (1) communications with an attorney acting as a legal advisor and relating to legal advice; or (2) material created in preparation for trial that would reveal the theories, mental impressions or litigation plans of the attorney.”

Additionally, the Attorney General found that the exemption concerning predecisional and deliberative materials (Section 7(1)(f)) did not apply because the IDOC failed to provide the Public Access Counselor “with a factual basis for [the IDOC’s] assertion that the records at issue constitute records in which opinions are expressed, or actions or policies are formulated.”


Author: Jacob D. Caudill

Friday, June 2nd, 2017

IHSA Not Subject to FOIA

In Better Gov’t Ass’n v. Ill. High Sch. Ass’n, 2017 IL 121124, the Illinois Supreme Court decided whether the Illinois Freedom of Information Act (“FOIA”) (5 ILCS 140/2) applied to the records maintained by the Illinois High School Association (“IHSA”). In June 2014, the Better Government Association (“BGA”) submitted a FOIA request to the IHSA seeking its contracts for accounting, legal, sponsorship, and public relations/crisis communications services and all licensed vendor applications for the 2012-2013 and 2013-2014 fiscal years. The BGA’s request specifically identified contracts between the IHSA and several entities. The IHSA responded that it was not subject to FOIA by citing its non-for-profit status. The BGA subsequently requested the same records from District 230 under section 7(2) under the premise that the IHSA performed governmental functions on behalf of the District. The District responded to the request by stating that it did not have any documents that were responsive to the request and that the requested documents did not fall within section 7(2). The BGA filed a complaint in the Cook County Circuit Court requesting a declaratory judgment that both the IHSA and District 230 violated FOIA. Both the IHSA and District 230 filed motions to dismiss which were granted by the trial court. The BGA appealed the dismissal and the appellate court affirmed.  Thereafter, the BGA appealed to the Illinois Supreme Court.

The question presented before the Illinois Supreme Court was whether the IHSA is a “public body” as defined by FOIA and whether the records requested by the BGA should be considered “public records” of District 230 for purposes of section 7(2) of FOIA. Prior to applying the four-factor test to determine if the IHSA is a public body under FOIA, the Court discussed the organization and establishment of the IHSA. The IHSA was founded in 1900 as a private, not-for-profit, unincorporated association of public and private high school members. Any public or private school may join the IHSA if it agrees to abide by the IHSA rules. The IHSA establishes and enforces various rules pertaining to interscholastic sport competition and it sponsors and coordinates post-season tournaments for certain sports in which its members compete.

Prior to applying the fourth-factor test to determine if the IHSA was a public body for purposes of the FOIA, the Court discussed the definition of a “public body” under the Act.  Section 2(a) defines the term “public body” as follows:

“all legislative, executive, administrative, or advisory bodies of the State, state universities and colleges, counties, townships, cities, villages, incorporated towns, school districts and all other municipal corporations, boards, bureaus, committees, or commissions of this State, any subsidiary bodies of any of the foregoing including but not limited to committees and subcommittees thereof.”

The Court stated that the IHSA did not fall within any of the specifically enumerated bodies in section 2(a).  As a result, for the IHSA to be subject to FOIA, it must qualify as a subsidiary body of one of the governmental units listed in section 2(a). The Court noted that FOIA does not define the term “subsidiary body.” As a result, the Court looked to the dictionary definition of “subsidiary.” Webster’s Dictionary defines “subsidiary” as an entity “belonging to or controlled by another.” Black’s Law Dictionary defines “subsidiary” as “subordinate; under another’s control.”  The Court noted that, prior to this case, it had not considered if a private entity could be considered a “subsidiary body” under FOIA.  The Court looked to the appellate court’s review of this issue for purposes of the Open Meetings Act for guidance.  The Appellate Court’s four-factor test used to determine whether a private entity could be a “subsidiary body” consisted of the following factors: (1) the extent to which the entity has a legal existence independent of government resolution, (2) the degree of government control exerted over the entity, (3) the extent to which the entity is publicly funded, and (4) the nature of the functions performed by the entity.  No one factor is more determinative or conclusive in the analysis.

The Court found that the first factor weighed against a finding that the IHSA is a public body.  In support of this conclusion, the Court cited to the fact that the IHSA was not created by a school district or any other public body or by any state statute or resolution. Additionally, the IHSA has never been “housed” within a public body and the board is not formally created by any public body.  The Court found that the second factor weighed against a finding that the IHSA is a public body.  In support of its conclusion on this factor, the Court found that no public body controls how the governing board is established or comprised.  Additionally, the IHSA does not need approval from any public body prior to taking any action.  Furthermore, the executive director and staff of the IHSA are not governmental employees, do not receive payment from governmental funds, are not subject to state regulations for public employees, and they do not participate in state or local government retirement or insurance programs.

The Court found that the third factor weighed against a finding that the IHSA is a public body. The Court found that the IHSA does not receive any direct governmental funds. Although the IHSA has the capacity to charge its member schools’ dues and/or entry fees to participate in its events, it does not charge its members. The organization is funded by revenue from ticket sales and donations. The Court declined to analyze the fourth factor stating that even if the Court were to find that it weighed in favor of a finding that the IHSA was a public body, this factor alone was not enough to transform a private entity into a public body for purposes of FOIA.

The Court next turned to whether the records sought from District 230 fell within section 7(2) of FOIA.  Section 7(2) provides as follows:

“A public record that is not in the possession of a public body but is in the possession of a party with whom the agency has contracted to perform a governmental function on behalf of the public body, and that directly relates to the governmental function and is not otherwise exempt under this Act, shall be considered a public record of the public body, for purposes of this Act.”

The Court noted that the BGA did not allege in its complaint that the District contracted with the IHSA to perform a governmental function.  The Court held that the District is not authorized to perform the functions of the IHSA and, as a result, the IHSA is not acting on behalf of the District to perform the District’s responsibilities.  Additionally, the Court held that the District had not delegated any of its responsibilities to the IHSA.

Kevin A. Chrzanowski

Author: Kevin A. Chrzanowski

Friday, June 2nd, 2017

Illinois Attorney General Issues Third Binding Opinion of 2017

Last week, the Illinois Attorney General’s Office issued its third  binding Public Access Opinion of 2017. In dispute was whether a sanitary district was exempt from disclosing contracts, budgets, and invoices with a company, Veolia, pursuant to section 7(1)(g) of Illinois’s Freedom of Information Act. For reference, Section 7(1)(g) exempts information which would disclose trade secrets.

At issue was whether the sanitary district had properly redacted 1,470 pages of records. These reductions included “most of the substantive financial terms of the contractual agreements, including but not limited to the annual base fee that the District is required to pay Veolia and information concerning modifications to that fee, as well as indemnity, liability, and insurance provisions. The District also redacted from the invoices the amounts that Veolia billed the District and the payment terms. In addition, the District redacted from the annual budgets submitted by Veolia the proposed monthly amounts and other total amounts to be paid to Veolia, as well as itemized costs of various services and expenses.” In so redacting, the sanitary district emphasized that it was prevented from disclosing such material because of a confidentiality clause in the contract with Veolia and asserted that Section 7(1)(g) exempted the requested material from disclosure.  The Section 7(1)(g) exemption reads as follows:

(g) Trade secrets and commercial or financial information obtained from a person or business where the trade secrets or commercial or financial information are furnished under a claim that they are proprietary, privileged or confidential, and that disclosure of the trade secrets or commercial or financial information would cause competitive harm to the person or business, and only insofar as the claim directly applies to the records requested.

However, the Attorney General rejected this exemption as applicable, because the confidentiality agreement specifically allowed for the disclosure of information that was “required to be disclosed by operation of law.” Specifically, the Attorney General found that Section 2.5 of FOIA and the Illinois Constitution compelled disclosure. Under Section 2.5 “[a]ll records relating to the obligation, receipt, and use of public funds of the State units of local government, and school districts are public records subject to inspection and copying by the public.” Additionally, Article VIII, Section 1(c) of the Illinois Constitution states that “[r]eports and records of the obligation, receipt and use of public funds of the State, units of local government and school districts are public records available for inspection by the public according to law.”

As such, the Attorney General found that the sanitary district violated the Freedom of Information Act, as the Illinois Constitution and Section 2.5 trumped any reliance on the confidentiality clause.


Author: Jacob D. Caudill

Thursday, May 18th, 2017

FOIA: The Blurry Line Between a Public College Foundation and a Public Body

The Second District Appellate Court ruled that the Foundation for the College of DuPage was so sufficiently intertwined with the College that records in the Foundation’s possession were subject to disclosure under the Freedom of Information Act (FOIA).

The underlying facts are that the Chicago Tribune submitted a FOIA request to the College and the Foundation, seeking documents and a specific grand jury subpoena. The College initially claimed it had no responsive documents before producing all documents except the subpoena (which it claimed it did not possess), while the Foundation claimed that it was exempt from FOIA because it was not a public body and any documents in its possession were not public records.

The Appellate Court affirmed the trial court’s ruling that while the Foundation was not, in itself, a public body, it was performing public functions. Some of the relevant aspects of the relationship between the Foundation and College included: the Foundation handled all fundraising efforts, along with collections and disbursements of private donations for the College, the College offered its employees to assist the Foundation in performing its functions, Foundation employees were provided benefits as though they were College employees, and College employees were involved in positions of influence on the Foundation. Much of the relationship between the Foundation and College was memorialized in a Memorandum of Understanding executed by the boards of each entity.

Having found that the Foundation was fulfilling public functions, documents in its possession that pertained to those public functions were thereby subject to FOIA.

An important legal aspect of the case was that the Second District largely eviscerated a First District interpretation of a key FOIA provision. The College argued, based on the prior case, that in order for it to provide documents responsive to a FOIA request, the “public records” sought must, generally, pertain “to the transaction of public business” and/or have been created, used, or controlled by the College. The subtle implication being that only a narrow set of documents that are in the possession of a third party would be subject to FOIA. Specifically, the College asserted that because it did not retain the subpoena sought by the FOIA request and because the subpoena did not meet the narrow definition of a public record pertaining to a third party, neither the College nor the Foundation were obligated to produce the subpoena.

The Court dismissed this argument stating that it would create an absurdity that public documents could effectively be hidden from the public by simply outsourcing the creation and storage of documents to a third party, such as the Foundation. While the decision is seemingly logical, the College made a good, albeit unsuccessful, argument based on prior case law interpreting the same provisions.

There are two main takeaways from the case:

  • Whether or not a foundation (or contractor or other third party) is actually a subsidiary of a public body does not change its responsibility to respond to FOIA documents, as would the public body itself, so long as the documents pertain to the foundation performing public functions
  • Several park districts, park departments, and community colleges have foundation boards, and both the public entity and the foundation should be aware of the functions and relationship of each entity, because there may be implications for FOIA as well as other areas of law.

Brad Stewart

Author: Brad Stewart

Thursday, May 18th, 2017

Federal Appellate Court Upholds Donation Bin Ordinance

Last week, the Federal Ninth Circuit Appellate Court decided a case concerning the constitutionality of an ordinance regulating Unattended Donation Collection Boxes (UDCB). Specifically, a non-profit operator of UDCBs sought an injunction against the City of Oakland, California, alleging that the City’s UDCB licensing ordinance violated the First Amendment.

The ordinance at issue defined UDCBs as “unstaffed drop-off boxes, containers, receptacles, or similar facility that accept textiles, shoes, books and/or other salvageable personal property items to be used by the operator for distribution, resale, or recycling.” With some exceptions, the Ordinance made it “unlawful to place, operate, maintain, or allow a UDCB on any real property unless the parcel owner/agent and/or operator first obtain[s] an annually renewable UDCB permit from the City.” In obtaining a permit, the operator must pay a $535 application fee (annual renewal fee is $246), propose a site plan, and obtain at least $1 million in liability insurance. Additionally, the Ordinance places further restrictions on “box placement location and size, requires specific periodic maintenance, and prohibits placing a UDCB within one thousand feet of another UDCB.”

In determining whether the ordinance violated the First Amendment, the Court was ultimately tasked with determining if the Ordinance was content based or content neutral. The Court reviews all content based restrictions under strict scrutiny. However, if “such a law does not suppress expression out of concern for its likely communicative impact, [courts] ordinarily apply intermediate scrutiny.” Courts, in deciding if a regulation is content based, first “consider whether a regulation of speech ‘on its face’ draws distinctions based on the message a speaker conveys.” The Ordinance will also be subject to strict scrutiny if the regulation “is facially neutral but cannot be justified without reference to the content of the regulated speech or was adopted by the government because of disagreement with the message the speech conveys.” The court ultimately decided that Oakland’s “Ordinance is content neutral because it does not, on its face, discriminate on the basis of content; can be justified without reference to the content of the regulated speech; and there is no evidence that Oakland adopted the Ordinance because it disagreed with the message conveyed by UDCBs.”

In coming to this conclusion, the court rebuffed an argument that the Ordinance was content based because an “enforcing officer would have to examine a container’s message and determine whether the container solicits charitable donations to determine whether the container was subject to the Ordinance’s requirements.” This argument failed for two reasons. First, the Ordinance is not limited to UDCBs soliciting charitable donations, as the Ordinance applies to any unattended structure that accepts items “for distribution, resale, or recycling.” The Ordinance applies regardless of whether the UDCB operator is collecting for charitable reasons or for-profit activities (in fact, Oakland’s largest UDCB operator was a for-profit company). Secondly, courts have “never held, or suggested, that it is improper to look at the content of an oral or written statement in order to determine whether a rule of law applies to a course of conduct.” The Court went on to state that “[i]f applied without common sense, this principle would mean that every sign, except a blank sign, would be content based.”

Interestingly, the Court distinguished this case from a 2015 Federal Sixth Circuit opinion which found a UDCB ordinance to be unconstitutional. Specifically, the Sixth Circuit held that a municipality’s “ordinance banning UDCBs collecting charitable donations was content based not because it required enforcing officers to look just at the message a UDCB itself was expressing, but because it required officers to look for a specific message soliciting charitable donations.” This Court therefore differentiated Oakland’s ordinance from the ordinance at issue in the Sixth Circuit case which “targeted only those bins engaging in a specific kind of protected expression.”

After finding that the Ordinance was content neutral, the Court also determined that the Ordinance survived intermediate scrutiny. The City argued that their regulation promoted a substantial government interest because the Ordinance was implemented to combat blight, illegal dumping, graffiti, and traffic impediments that endanger drivers and pedestrians.

To conclude, this opinion provides much needed guidance to municipalities who wish to enact an ordinance to combat the proliferation of Unattended Donation Collection Boxes.


Author: Jacob D. Caudill