Howell Educ. Assoc. MEA/NEA v. Howell Board of Educ., 2010 WL 290515 (Jan. 26, 2010)

Key Insight: Reversing the trial court, appellate court found personal emails retained on public school?s email system were not public records and therefore not subject to disclosure pursuant to Michigan?s Freedom of Information Act; court also concluded that violation of an acceptable use policy that does not expressly provide that emails are subject to FOIA does not render personal emails subject to disclosure pursuant to FOIA

Nature of Case: FOIA

Electronic Data Involved: Personal emails