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Michigan FOIA Requires Particularized Explanation of Reasons for Denying Records Requests

The Evening News Association (News) requested documents associated with the investigation of a homicide committed by a police officer, pursuant to the state Freedom of Information Act (FOIA), Mich. Comp. Laws § 15.231 et seq. (Mich. Stat. Ann. § 1801(14)(1) et seq.). The City of Troy (City) refused, saying only that the same would interfere with the investigation. The News filed suit to compel disclosure. The trial court dismissed, and the News appealed.

On appeal, the Supreme Court of Michigan found that the FOIA required the City to explain how its investigation would be compromised by disclosing the requested records. On that basis, it reversed and remanded the case to the trial court for further proceedings. See: The Evening News Ass’n v. City of Troy, 417 Mich. 481; 330 N.W.2d 421 (1983).

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Related legal case

The Evening News Ass’n v. City of Troy