Breighner v. MICH. HIGH SCHOOL ATHLETIC ASS'N, INC.

At issue in this case is whether defendant Michigan High School Athletic Association, Inc. (MH-SAA), a private, nonprofit entity that organizes and supervises interscholastic athletic events for its voluntary members, is a “public body” as that term is defined at MCL 15.232(d) of the Freedom of Information Act (FOIA), MCL 15.231 et seq. Plaintiffs contend that the MHSAA is a public body within the meaning of the FOIA because (1) it is “primarily funded by or through state or local authority,” MCL 15.232(d)(iv); (2) it is “created by state or local authority,” MCL 15.232(d)(iv); and (3) it is…