Below is CJP’s FOIA in the Sgt. Khalil Muhammad case to the City of Chicago Law Department in his unjustified shooting, and subsequent murder, of Ricardo “Ricky” Hayes in the Chicago's Morgan Park Neighborhood back in August of 2017.

This is part of a series of FOIAs that the Chicago Justice Project is filing to shed light on the highly questionable mediation of his pending termination case in front of the Chicago Police Board that resulted in a plea agreement of a 180 day suspension rather than termination. As we file the subsequent FOIAs we will be posting links. Also we will be posting responses we get from the agencies. You can find links to all of our FOIAs in in this case here.

Below is the content of our FOIA we filed with the City of Chicago Law Department on 2/18/2020.

In accordance with Definitions and Instructions below and the Illinois Freedom of Information Act, 5 ILCS 140, I request that your office provide the following public records: 

1. All video and audio recordings of any kind of Sgt. Khalil Muhammad’s Aug. 13, 2017 off-duty shooting of unarmed teenager Ricardo “Ricky” Hayes in the Morgan Park neighborhood of Chicago (the “Incident”) –Board Case # 19 PB 2956.  Without limiting the scope of this FOIA request in any way, the response to this request should include at a minimum all of the following:

a. Electronic recordings from cell phones

b. Electronic recordings from nearby security cameras collected by Police as evidence or otherwise

c. Bodycam footage from Muhammad.

d. Surveillance video showing Muhammad driving past Hayes without stopping.

e. Video of the Incident reviewed by any members of the Board.

f. Video of the Incident reviewed by any hearing officers employed by the Board.

2. All documents regarding the “Incident”.  Without limiting the scope of this FOIA request in any way, the response to this request should include at a minimum all of the following:

a. Police reports regarding the Incident.

b. Statements regarding the Incident.

c. Evidence reviewed or considered by members of the Board regarding the Incident.

d. Evidence reviewed or considered by any hearing officers employed by the Board regarding the Incident.

e. Evidence in the Record of Proceedings before the Board.

f. The “stipulation” filed by the City with the Board in October, 2019, including all 11 exhibits to same.

3. Any documents or motions field by the City with the Board regarding the Incident.

4. Any charges filed by the City with the Board regarding the Incident.

5. Any final decisions handed down by the Board regarding the Incident. All documents regarding the “Plea Agreement”.

6. All documents regarding the Board’s decision not to fire Muhammad.

7. All documents regarding the Board’s decision that Muhammad’s use of deadly force was unjustified.

8. The transcript and/or any notes or recordings (or documents reflecting) Muhammad’s statement(s) about the Incident.  Without limiting the scope of this FOIA request in any way, the response to this request should include at a minimum all of the following:

a. Muhammad’s statement(s) to the Police.

b. Muhammad’s statement(s) to COPA.

9. COPA’s summary and findings about the Incident.

10. All documents (including electronic documents and communications) refer...