FOIA request; MCL 15.235(1); Effect of a denial; MCL 15.240(1)(b); Principle that appellate review is limited to the trial court record; Amorello v Monsanto Corp; Principle that parties must fully present their legal arguments to the court; Walters v Nadell; Principle that courts will not develop arguments for an appellant; Mitcham v Detroit

The court held that “when plaintiff failed to state or support his claim, the trial court did not err when it granted” defendant summary disposition in this FOIA case. Plaintiff sued defendant-county related to his requests for information under the FOIA. The trial court found that his “complaint did not explain what information [he] had requested or when [he] had been denied information. Plaintiff’s daughter clarified that [he] was seeking information regarding his real property and that his FOIA requests to defendant had been denied or left unanswered. The trial court explained to plaintiff and his daughter that plaintiff needed to submit a ‘clearly labeled’ FOIA request.” On appeal, the court noted “several critical problems with plaintiff’s appeal.” First, the attachments he presented “on appeal that were not attached to, or even referenced in, his complaint, and were never filed with, or considered by, the trial court,” were not properly before the court. As such, it declined to “consider the improperly submitted documents.” Second, the trial court “did not err by determining that plaintiff failed to state clearly his claims or requested relief.” Plaintiff asked the court to “‘interpret FOIA Law as cited on brief and complaint,’ alleging that his requests for information were ignored or denied. In the lower court, however, [he] did not identify or present any specific FOIA denials, appeals, or related correspondence from defendant, nor did [he] clearly identify what information or equitable relief he sought.” Third, an appellant may not “‘simply [] announce a position or assert an error and then leave it up to [the court] to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments.’” Plaintiff listed “eight questions presented in his brief on appeal, which generally relate to FOIA and the trial court’s decision.” But he did not “provide a comprehensible argument or explanation as to how the authorities that he cites support his claims and requested relief.” Affirmed.