Freedom of Information Act (FOIA); Body-camera footage; Law Enforcement Body-Worn Camera Privacy Act; MCL 780.315; Law-enforcement-proceedings exemption; MCL 15.243(1)(b)(i); Fair-trial exemption; MCL 15.243(1)(b)(ii); Privacy exemptions; MCL 15.243(1)(a) & (b)(iii); Redaction; Completed ballots; Witness interviews; Personal contact information; Fees, costs, & disbursements; Punitive damages; Civil fines

The court held that the trial court erred by withholding all requested body-camera footage under the law-enforcement-proceedings exemption, but some portions were exempt under privacy exemptions. Plaintiff-journalist sought body-camera footage from an election-day arrest at a polling place. The trial court granted defendant summary disposition after in camera review. On appeal, the court first held that the FOIA request sufficiently identified the videos because a requester need only describe records “sufficiently to enable the public body to find” them. The court next held that defendant failed to justify the law-enforcement and fair-trial exemptions. It reasoned that a public body must provide “complete particularized justification,” not a “simple repetition of statutory language,” and defendant’s affidavit did not explain how disclosure would interfere with proceedings or deny a fair trial. The court then held that some privacy exemptions applied. Personal contact information was exempt, and witness interviews contained “embarrassing or intimate details” about the witnesses’ actions and personal lives. But voters visible in the background were not exempt because a voter’s identity is not “information of a personal nature,” and only how a person voted is private. The court remanded for the trial court to determine whether completed ballots appear in the footage because a completed ballot is “private or confidential information.” Finally, the court held that plaintiff partially prevailed and the trial court must consider costs, but punitive damages and civil fines were unwarranted because defendant’s mistaken denial was not arbitrary, capricious, willful, or in bad faith. Affirmed in part, reversed in part, and remanded.