FOIA; Pending-litigation exemption; MCL 15.243(1)(v); Certified copy; MCL 15.233(6); Creation of new public record; MCL 15.233(5); County board certification; MCL 46.4; County board records; MCL 46.29; Mootness; Motion to strike counsel; Standing; MCR 2.605; Frivolous claims & filings; MCL 600.2591; MCR 1.109(E); Department of Wayne County Clerk (WCC)

The court held that plaintiff’s FOIA claims were moot, he lacked standing to strike defendants’ counsel’s appearances, and the trial court did not err by finding some of his claims and his motion to strike frivolous. Plaintiff sued after seeking certified copies of county commission resolutions from defendants-Commission and the WCC. The trial court granted defendants summary disposition, reasoning that the requested documents had been produced or did not exist, and it found Counts I and III and plaintiff’s motion to strike frivolous. On appeal, the court first held that the FOIA claims were moot because the requested records had been produced, and plaintiff’s certification argument failed. It reasoned the FOIA required only that the custodian furnish a “certified copy” that authenticated the copy as “a true and genuine reproduction of the existing public record,” not a document separately certified under MCL 46.4 or MCL 46.29. The court also held that plaintiff lacked standing to challenge a law firm’s representation of two defendants because his standing to seek declaratory relief did not “by itself, confer standing to bring the motion to strike.” Finally, the court held that the sanctions rulings were proper. Count I “served no legitimate purpose” because the Commission had already responded to plaintiff’s request, Count III rested on a certification theory “multiple trial courts had soundly rejected,” and the motion to strike repeated unsuccessful arguments while ignoring prior documentation that the Commission approved the retention. Affirmed.