After a public body denied a FOIA request for emails based on applicable FOIA exemptions, the requestor sued the public body claiming that the records were improperly withheld. After conducting an “in-camera” inspection of the records that had been withheld from release, the trial court agreed that the records were properly exempt from disclosure, and the requester appealed.

On appeal, the requestor argued that the withheld responsive records could be redacted to protect certain exempt information and released to the requester. However, because the record on appeal did not include the emails that had been reviewed by the trial court, the appellate court presumed that the trial court’s order was in conformity with law and had a sufficient factual basis and upheld the ruling in favor of the public body. Robinson v. Township High School District 113 

Post Authored by Eugene Bolotnikov, Ancel Glink