Fee for providing a copy of a public record; Indigent discount; MCL 15.234(2); Abandoning an argument by failing to properly present it

Concluding that MCL 15.234(2) “explicitly outlines the framework for deductions from fees, setting forth a permissible deduction amount of $20[,]” the court held that this statutory language supported defendant’s action in giving plaintiff only the $20 discount. Thus, it affirmed the trial court’s order granting defendant summary disposition in this FOIA action. “Plaintiff filed an FOIA request seeking 11 items, namely texts and emails of elected officials and department heads employed with” defendant. He was informed that the costs to process his “request totaled $13,604.86. After applying a $20 waiver for indigent persons and a $678.99 reduction for defendant’s late response, the total amount due came to $12,905.87.” The issue on appeal was whether he was “entitled to a discount greater than the $20 given to him by defendant.” The court noted “MCL 15.234(2) clearly states that indigent individuals and certain nonprofit organizations are entitled to receive copies without charge for the first $20 of the fee. Any statutory reductions beyond that are not listed in plaintiff’s brief, nor does he cite to case law that requires defendant to provide [him] a greater discount. To the extent” he challenged the charged fees on alternative grounds, the court found he simply “claimed that the trial court’s ruling was incorrect, without addressing [its] reasoning or providing relevant legal authority to bolster his assertions.” It concluded that he “effectively abandoned these arguments due to his inadequate briefing and failure to address and point to the error in the trial court’s rationale.” It added that even if it were to consider his additional arguments, none of them altered “the fact that the trial court properly relied on the clear language of MCL 15.234(2).”