Robert Davis v. City of Highland Park

Michigan Court of Appeals·Decided July 22, 2026·No. 370994·Unpublished

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

ROBERT DAVIS, UNPUBLISHED July 22, 2026 Plaintiff-Appellant, 2:50 PM

v No. 370994 Wayne Circuit Court CITY OF HIGHLAND PARK, LC No. 23-010741-CZ

Defendant,

and

DEPARTMENT OF WAYNE COUNTY CLERK, WAYNE COUNTY EMPLOYEES’ RETIREMENT SYSTEM, and WAYNE COUNTY RETIREMENT COMMISSION,

Defendants-Appellees,

WAYNE COUNTY BOARD OF COMMISSIONERS,

Intervening Defendant-Appellee.

Before: MALDONADO, P.J., and RIORDAN and YOUNG, JJ.

PER CURIAM.

In this action brought under the Freedom of Information Act (FOIA), MCL 15.231 et seq., plaintiff Robert Davis challenges the trial court’s rulings related to two different and unrelated FOIA requests to different public bodies. For the first challenge, plaintiff argues that the trial court erred by granting motions for reconsideration that dismissed his claim against the defendant Department of Wayne County Clerk (WCC). For the second challenge, plaintiff argues that the trial court erred by granting summary disposition in favor of the defendants Wayne County

-1- Employees’ Retirement System and the Wayne County Retirement Commission (collectively, the retirement defendants). For the reasons explained below, we affirm in part and reverse in part, and remand to the trial court for further proceedings.

I. BASIC FACTS

This case arises from two separate and unrelated requests plaintiff made pursuant to the FOIA.1

A. REQUEST FOR ORDINANCE NO. 83-13

On April 9, 2023, plaintiff sent one e-mail to multiple recipients: Felicia Johnson,2 Wayne County Clerk Cathy M. Garrett, and Pamela Lane, the Deputy County Clerk. Plaintiff cc’d other addresses as well, including one labeled “foiarequests@waynecounty.com.” The e-mail made the following request:

Pursuant to Michigan’s Freedom of Information Act (FOIA), and MCL 46.4 and 46.5, I am respectfully requesting certified copies of the following public documents:

1. Certified copies of Wayne County Ordinance No. 83-13 and any subsequent amendments made thereto by the Wayne County Commission.

Please send all responses to this FOIA request to this email address.

In a letter, which was sent via e-mail on April 17, 2023, Johnson replied, stating in relevant part:

This response only pertains to records within the possession of the Commission and is provided pursuant to the Michigan Freedom of Information Act, Public Act 442 of 1976 (“FOIA”).

Your request is denied because Ordinance No 83-13 does not exist. After a diligent search for the requested records, we have determined and certify that these records do not exist within the records of the Commission.

* * *

1 A third FOIA request that also was a subject of this case was made to defendant City of Highland Park, but plaintiff and Highland Park settled that claim. Consequently, neither Highland Park nor that particular FOIA request is pertinent for the issues on appeal. 2 Johnson is the Wayne County Commission Counsel and the FOIA Officer for the Wayne County Commission.

-2- Your request has also been forwarded to executive departments for review and response to the extent they have records responsive to your request.

There is no dispute that the WCC did not provide a separate response.

B. REQUEST FOR RETIREMENT INFORMATION

On June 23, 2023, plaintiff sent a FOIA request to the retirement defendants, seeking the following:

Copies of any and all written documentation that explains the retirement benefits Alan Helmkamp will receive from the Wayne County Employees’ Retirement System when he retires from the County of Wayne.

On June 29, 2023, counsel for the retirement defendants responded and granted plaintiff’s request. The letter stated that the “[w]ritten documents that best ‘explains the retirement benefits Alan Helmkamp will receive’ would be the Retirement System’s plan documents which are available on the Retirement Systems website . . . .” The web address was provided.

Plaintiff immediately responded, averring that the communication was not responsive to the “very specific and accurately identified . . . documents . . . requested.”

C. FILING OF THE COMPLAINT

Plaintiff filed the instant three-count complaint on August 21, 2023. For purposes of the present appeal, only Counts II and III are relevant.3 Count II sought a declaratory judgment that (1) pursuant to MCL 46.4, the Wayne County Clerk is the clerk of the Wayne County Board of Commissioners (WCBC); (2) the WCC violated MCL 15.235 of the FOIA by failing to timely respond to plaintiff’s April 9, 2023 request; and (3) the documents plaintiff requested are subject to disclosure under the FOIA. Count III sought a declaratory judgment that the retirement defendants violated the FOIA by failing to provide responsive documents to plaintiff’s June 23, 2023 request. Contemporaneous with his complaint, plaintiff also filed a motion seeking declaratory relief related to Counts I and II of the complaint.4

D. PROCEDURAL HISTORY—ORDINANCE REQUEST

The WCBC intervened as an intervening defendant and argued that plaintiff’s motion for declaratory judgment in Count II should not be granted. Shortly thereafter, the WCC moved for summary disposition. The WCC argued that the claim against it should be dismissed because (1) plaintiff has no right to receive a copy of an ordinance that does not exist; (2) after receiving a response from the Wayne County Commission FOIA coordinator, plaintiff has no right to receive

3 Count I pertained to defendant Highland Park, which settled the claim and was dismissed from the action. See note one of this opinion. 4 With respect to the pertinent Count II, the verbiage appears to be identical in both the motion for declaratory judgment and the complaint.

-3- a separate response from the WCC; and (3) the WCC does not have a separate duty to certify ordinances in relation to FOIA requests.

The trial court first ruled that plaintiff’s reliance on MCL 46.4 and 46.11(j) was misplaced because those statutes do not pertain to a board of commissioners. The trial court denied the WCC’s motion for summary disposition. The trial court noted that the WCC failed to cite any authority for its position that it did not have to provide a separate response to plaintiff’s FOIA request after the WCBC provided a response. The trial court also stressed that, accepting that Ordinance No. 83-13 did not exist, the WCC nevertheless had a duty to timely respond to plaintiff informing him of the nonexistence. As a result, the trial court denied the WCC’s request for summary disposition under MCR 2.116(C)(8) and, pursuant to MCR 2.116(I)(2), instead granted summary disposition in favor of plaintiff.5

On November 9, 2023, the WCBC and the WCC filed separate motions for reconsideration. They argued that the trial court misinterpreted MCL 15.232(h) in concluding that the component units (including the WCBC and the WCC) do not constitute one county (Wayne County). In other words, they alleged that a county and its constituent components, as a whole, is one public body, not distinct separate public bodies under the FOIA, thereby requiring only one response to a FOIA request.

The trial court granted the motions for reconsideration, finding the following passage from Densmore v Dep’t of Corrections, 203 Mich App 363, 366; 512 NW2d 72 (1994), persuasive:

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