Hopkins v. Duncan Township

Plaintiff appeals as of right an order granting summary disposition in favor of defendant on plaintiffs claim that defendant violated Michigan’s Freedom of Information Act (FOIA), MCL 15.231 et seq. We affirm, holding that handwritten notes of a township board member taken for his personal use, not circulated among other board members, not used in the creation of the minutes of any of the meetings, and retained or destroyed at his sole discretion, are not public records subject to disclosure under FOIA.

I. THE PARTIES’ PLEADINGS

On March 18, 2010, plaintiff filed a complaint alleging a FOIA…