Plaintiff filed a complaint asserting one claim under the Freedom of Information Act claiming that the County had improperly denied a FOIA request by failing to respond to a request for a copy of certain documents. However, the alleged FOIA request was located at the end of a lengthy response within an e-mail chain and did not expressly identify itself as a FOIA request. Separately, Plaintiff sued under the Open Meetings Act, claiming that the County had violated the OMA by failing to properly notice a change of venue of a County Board meeting after the County had initially relocated the meeting due to a flood that caused the elevator to the meeting room to be inoperable, but then moved it back to the County building when the elevator was repaired prior to the meeting. Affirming the trial court’s of summary disposition to the County, the Court of Appeals found that no FOIA violation had occurred because the request for records did not satisfy the requirements for a proper FOIA request, and therefore, the non-response did not constitute an actionable denial. Additionally, Plaintiff had no recourse relating to the OMA claim, as the County re-enacted the business of the adjourned meeting, there was no evidence of ongoing OMA violations requiring injunctive relief, and no actual controversy existed requiring declaratory relief to guide the parties’ future conduct.





